Slavery and human trafficking are a stain on our global society. We all have a responsibility to be alert to the risks, however small, in our own business and in supply chains which we influence at our clients.
JMCL Consulting Ltd (JMCL)) is committed to maintaining and eradicating modern slavery or human trafficking from its own supply chains or in any part of its business and encourages that commitment from its clients and suppliers and they, in turn, from their supply chains. We encourage our employees and associates to do the same with their own supply chains and business practices.
We act ethically, morally and with integrity in all our business dealings and relationships and take all reasonable steps to ensure slavery and human trafficking are not taking place in any business or organisation that has any business relationship with JMCL.
JMCL trades ethically, sources responsibly and works to prevent modern slavery and human trafficking throughout its supply chains. We support financially and are in contact with Hope for Justice an organisation working in the UK, USA, Ethiopia and Uganda to bring freedom from human trafficking and modern slavery by identifying victims, supporting survivors and preventing exploitation. We also work with individuals in Freetown, Sierra Leone to promote education and welfare and avoid people falling into slavery or trafficking.
This statement describes key activities which we undertake to combat modern slavery in JMCL, including how we hold suppliers and clients to account in our contractual relationships in a bid to identify and prevent the risk of modern slavery. We are a UK-based business with international clients, and although our annual turnover falls below the threshold that mandates we publish a modern slavery and human trafficking statement, under section 54(1) of the Modern Slavery Act 2015, we are voluntarily publishing our position and approach to modern slavery to signal our commitment.
JMCL has a takes a zero-tolerance approach to slavery and human trafficking. We expect all those in our supply chain and all contractors to comply with our values.
As part of our initiative to identify and mitigate risk, JMCL has in place systems to encourage the reporting of concerns and the protection of whistle blowers and we would encourage anyone working in or with JMCL be they employees, consultants or contractors, who has suspicions about a particular supplier or client or client supplier to highlight those to JMCL’s CEO.
We favour using reputable suppliers and prefer to work with suppliers that are based in jurisdictions that are low risk for modern slavery, wherever possible. We expect these entities to have suitable anti-slavery and human trafficking policies and processes.
JMCL’s induction includes highlighting our policies, procedures and expectations, including this modern slavery and human trafficking statement.
JMCL uses the following KPIs to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
Level of adherence to procurement policies and processes
Maintenance of a level of communication and personal contact with the next link in the supply chain to ensure their understanding of, and compliance with, our expectations.
Regularly review of supply chain policies, codes of conduct and our working practices to show commitment.
JMCL expects the suppliers and clients with which it works to have included modern slavery clauses in their contracts with it, backed up by modern slavery statements/policies and, where they have not, pushes for inclusion of these commitments. Our public sector clients recognise their obligations to tackle modern slavery, in accordance with government guidance, and customarily include these clauses in their agreements with us, as well as including these obligations in their contracts and tender documents for public procurement within their supply chains. Many JMCL clients, particularly those in the public sector, encourage payment of individuals at the living wage, rather than minimum wage, within their tenders and supply chains.
JMCL is conscious that its employees and contractors are the ones who may be closest to a particular client or supplier and will be the ones who are knowledgeable about practices. With that in mind, employees or contractors should report any suspicions of slavery either to JMCL’s CEO or externally to the Modern Slavery and Exploitation Helpline using the following contact point: Modern Slavery Helpline
Jonny Michael Chief Executive Officer 5th January 2025
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