Modern Slavery and Human Trafficking Prevention Policy

JTG Consulting Group Ltd (“JTG” or the “Company”) is committed to conducting business ethically and responsibly, and to preventing modern slavery, human trafficking, forced labour and exploitation in its operations and business relationships. JTG maintains a zero-tolerance approach to these practices. This policy sets out expectations for identifying, reporting and addressing associated risks.

 

2. Scope

 

This policy applies to JTG employees, directors, officers, consultants, contractors and individuals acting on its behalf throughout the United Kingdom and EMEA. JTG also expects suppliers, recruitment agencies, subcontractors and other business partners to uphold equivalent standards.

 

3. Legal and Regulatory Framework

 

JTG will comply with applicable laws in the jurisdictions where it operates, including the UK Modern Slavery Act 2015 and relevant UK employment and immigration legislation, as well as applicable European and national laws concerning forced labour, human trafficking and human rights. JTG takes account of relevant International Labour Organization conventions and the UN Guiding Principles on Business and Human Rights. Legal obligations may vary by jurisdiction and by company size or activity.

 

4. Definitions

 

Modern slavery includes forced or compulsory labour, servitude, human trafficking, debt bondage and unlawful child labour. These practices can involve coercion, threats, deception, restrictions on movement, withholding of identity documents or exploitative debt arrangements.

 

5. Company Commitments

 

JTG will:

• Prohibit forced labour, human trafficking, servitude and unlawful child labour.

• Ensure employment is freely chosen and working conditions comply with applicable law.

• Pay workers lawfully and provide clear employment terms.

• Never retain passports or identity documents to restrict freedom of movement.

• Prohibit exploitative recruitment fees or practices.

• Encourage good-faith reporting and prohibit retaliation.

• Take proportionate action to address identified concerns.

 

6. Recruitment and Employment Practices

 

JTG will undertake applicable right-to-work checks, maintain appropriate employment records and communicate employment terms and compensation clearly. Employees may leave employment in accordance with lawful contractual notice requirements. JTG will not tolerate intimidation, coercion or unlawful restrictions on movement. Recruitment agencies and staffing providers are expected to follow ethical recruitment standards.

 

7. Suppliers, Contractors and Business Partners

 

JTG expects third parties to comply with applicable labour and human rights requirements. Where proportionate to risk, JTG may:

• Assess potential labour exploitation risks before or during engagement.

• Request policies, certifications or assurances of compliance.

• Include appropriate contractual obligations.

• Investigate credible allegations and require corrective action.

• Suspend or terminate relationships where appropriate, subject to contracts and consideration of impacts on affected people.

 

8. Risk Assessment and Due Diligence

 

As a healthcare IT and consulting services business, JTG will use a risk-based approach reflecting the nature and scale of its operations. Relevant exposure may arise through recruitment agencies, subcontracted professional services, technology procurement and suppliers in higher-risk jurisdictions. Identified concerns will be evaluated and appropriate safeguards or corrective measures determined.

 

9. Reporting Concerns

 

Anyone who suspects modern slavery or human trafficking should promptly report the concern to Human Resources, their manager, senior management or the Chief Executive Officer. Reports will be handled sensitively and confidentially to the extent reasonably possible and lawful. Retaliation for a good-faith report or participation in an investigation is prohibited. Where a person faces immediate danger, emergency services or the appropriate authorities should be contacted.

 

10. Investigation and Corrective Action

 

JTG will assess credible concerns fairly and promptly, with regard to the safety of affected individuals. Responses may include improving controls, requiring supplier remediation, additional monitoring, disciplinary action, ending a business relationship or notifying authorities where required or appropriate. Remediation decisions should avoid exposing potential victims to further harm.

 

11. Training and Awareness

 

JTG will make this policy available to relevant personnel and provide proportionate guidance or training, particularly for individuals involved in recruitment, contracting, procurement and supplier management.

 

12. Roles and Responsibilities

 

The Chief Executive Officer has overall accountability for this policy. Human Resources supports implementation, employee awareness and escalation of concerns. Managers must identify and escalate risks in their areas. All employees and contractors must comply with the policy and report suspected violations.

 

13. Monitoring and Review

 

JTG will periodically review the effectiveness of its measures, considering the size, nature and geographic reach of its activities. The policy will be reviewed at least annually and updated as needed for legal or operational changes.

 

14. Modern Slavery Transparency Statement

 

Where legally required, JTG will prepare, approve and publish a modern slavery statement meeting the applicable statutory requirements. Where no reporting obligation applies, JTG may voluntarily provide accurate information about its practices to customers and other stakeholders. This internal policy is not itself an annual statutory transparency statement.

 

15. Related Policies

 

This policy should be read alongside the Business Ethics Policy, Anti-Bribery and Corruption Policy, Anti-Money Laundering Policy, Prevention of the Facilitation of Tax Evasion Policy, and applicable whistleblowing, equality and anti-harassment policies.

 

16. Policy Compliance

 

Breaches may lead to disciplinary measures, termination of engagement or referral to authorities as appropriate and permitted by law. JTG may amend this policy to reflect legal, regulatory or business developments.

 

Effective Date: 10th July 2024

Policy Owner: Chief Executive Officer (CEO)

Approved By: Jamel Giuma, President & CEO

Last Reviewed: 1st January 2026

Next Review: 1st January 2027