Modern Slavery Act Transparency In Supply Chain Statement

  1. Introduction

    1.1 Square Enix Limited ("Square Enix") is a responsible corporate citizen.  Accordingly, Square Enix seeks to ensure that excellent quality and safety standards are maintained throughout its supply chain and its business by well treated, fairly compensated workers in accordance with all applicable laws.

    1.2 This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for Square Enix and its subsidiaries for the financial year ending 31 March 2018. 

  2. Corporate Structure

    2.1 Square Enix publishes and distributes interactive entertainment content.  It is a UK based and incorporated member of the Square Enix group of companies (the "Group"), which is a provider of entertainment products and services in the world.

    2.2 Square Enix has a number of subsidiaries across the globe covering various activities from design and development of interactive entertainment products to marketing and distribution within their local markets. The complete list of subsidiary companies is as follows:

        1. USA – Eidos Inc. and Crystal Dynamics Inc.
        2. Canada – Eidos Interactive Corp.
        3. UK – SCi Games Ltd, Eidos Ltd, Centregold Ltd and SCi Entertainment Group Ltd.
        4. France – Square Enix SARL.
        5. Germany – Square Enix GmbH.
        6. Denmark – IO Interactive Holdings A/S.
        7. China – Eidos Creative Software (Shanghai) Co. Ltd.

    2.3 This statement covers the steps taken by Square Enix to ensure that slavery and human trafficking is not occurring in its business or supply chain. It also reflects the Group-wide approach to slavery and human trafficking and the seriousness with which the Group takes its responsibilities in relation to such issues.  As such, the steps identified have, in part or in whole, been taken across the Group, including but not limited to Square Enix.

  1. Policies

    3.1 Square Enix is committed to ensuring that there is no slavery or human trafficking in any part of its business or its supply chains.

    3.2 The Group Code of Conduct requires Square Enix employees and executive officers to act with professional ethics and to conduct business fairly in strict compliance with the applicable law in the countries where Square Enix does business.

    3.3 The Group Code of Conduct also requires Group companies to pay attention to third party management conditions and track record when engaging with them.  It also requires Group companies to provide a wholesome and comfortable working environment for employees, in which they are treated fairly.

    3.4 Square Enix also has in place a Group whistleblowing system for employees to highlight potential misconduct including contravention of applicable laws or Group policy (including the Code of Conduct).

    3.5 A copy of the Code of Conduct can be read at:
    http://www.hd.square-enix.com/eng/company/philosophy.html

  2. Due diligence processes

    4.1 Square Enix currently believes the risk of slavery or human trafficking in its supply chain to be low. Square Enix therefore does not currently audit its suppliers for compliance.  However, Square Enix will consider increased measures, such as auditing or third party verification, for any suppliers that it determines are of medium or high risk.  If Square Enix suspects a supplier is involved in such activities, it will conduct an inquiry and, if necessary, terminate that supplier and/or take other corrective action immediately.

  3. Further Steps

    5.1 In light of our current assessment that the risk of modern slavery or human trafficking in our business or supply chain is low, Square Enix considers its current approach and compliance systems to be an appropriate and effective response to the risks it faces.  However, should Square Enix become aware of any information which may alter that risk assessment, it will consider what further steps may be appropriate.

Phil Rogers
Chief Executive Officer
Square Enix Ltd




Square Enix Group – UK Tax Strategy

The Square Enix Group (the ‘Group’, consisting of Square Enix Holdings Co., Ltd., a company incorporated in Japan and its subsidiaries) boasts a valuable portfolio of intellectual property including: FINAL FANTASY®, DRAGON QUEST®, TOMB RAIDER®, and SPACE INVADERS®.

Square Enix Limited is a London-based, wholly owned subsidiary of Square Enix Holdings Co., Ltd. Square Enix Limited (and subsidiaries) develop, publish, distribute and license SQUARE ENIX®, EIDOS® and TAITO® branded entertainment content in Europe and other PAL territories.

The Square Enix Group has the following UK companies, all of which are covered by this UK Tax strategy disclosure:

  • Square Enix Limited

  • Square Enix (2009) Limited

  • Eidos Ltd.

  • Centregold Limited

  • Sci Entertainment Group Limited

  • Sci Games Limited

This document has been approved by the Group Chief Financial Officer (CFO), and satisfies the disclosure requirements under Schedule 19 (2) of the UK Finance Act 2016.


Group Tax Strategy

The Group Tax strategy is approved by the Group CFO, and sets out the core principles that govern the tax policy for all Square Enix Group companies, including:

  • An important aspect of strong corporate social responsibility is tax transparency and a commitment to tax compliance;

  • Square Enix strives to pay the correct amount of tax, in the jurisdictions in which it is due at the right time in accordance with the tax laws and regulations of the countries in which it does business;

  • Paying the right taxes in these countries contributes to their economic and social development, which also benefits the Group.

The UK companies in the Square Enix Group all follow these principles in managing their tax affairs.


Tax Governance

Tax forms part of the accounting and finance function of the business. The Group CFO has overall responsibility for Group tax matters. Local Financial Directors (or equivalent) are responsible for tax in their local jurisdictions.

The business effectively manages tax risks through the timely gathering and sharing of information across the Group and regular communication between Group companies. There is regular communication between the Group CFO and the Western CFO in order to review worldwide tax issues.

In the UK, day-to-day tax operations are delegated to the UK Tax Accountant.

The UK Tax Accountant communicates regularly with staff from across the UK and Western business to keep informed of any changes, and monitors developments in tax legislation to understand its impact on the UK Group. The UK Tax Accountant is in regular contact with the UK Senior Financial Controller and the Western CFO, as well as relevant members of the Group’s Corporate Headquarters.

UK tax risks are managed in line with the overall Group Tax strategy, and follow business procedures and internal controls required to comply with J-SOX reporting rules. The UK Tax Accountant reviews UK specific risks and maintains a UK tax risk register. The UK Group companies nominate a Senior Accounting Officer (‘SAO’) who is responsible for ensuring that those companies establish and maintain appropriate tax accounting arrangements to allow tax liabilities to be calculated accurately in all material respects.


Approach to tax risks and tax planning

The Square Enix Group maintains a low tax-risk profile whilst maximizing long-term corporate value and fulfilling all tax responsibilities. The Group commits to not entering into tax avoidance arrangements or artificial planning that does not follow commercial reality or is at odds with the purpose of local legislation. Square Enix does not use tax havens for tax avoidance purposes.

The approach to tax in the UK is in line with the Group strategy, and where a tax treatment is uncertain, the impact on the Group is evaluated and resolved with an aim of maintaining low risk. The Group operates within a system of complex international tax rules, and therefore where there are matters of uncertainty; Square Enix will engage external professional advisors for support to ensure it remains fully compliant in the UK and overseas.

Where available and aligned with business activities, Square Enix will take advantage of available UK corporate tax reliefs for its activities, including those available for research and development and those specifically aimed at video games companies. Square Enix does not currently benefit from any such reliefs in the UK.

In the UK, Square Enix also contributes through payment and collection of a variety of other taxes including VAT, employment taxes (including national insurance), import duties and withholding taxes.


Relationship with HMRC

The Group seeks to foster a transparent, professional and cooperative approach to its relationship with HMRC. Where possible the Group will look to work in real-time with HMRC, seeking to clarify matters of uncertainty in advance, including engaging in Advance Pricing Agreements to confirm related party transactions with overseas affiliated companies.



Updated: 19 September 2018