Projective Group is committed to preventing slavery and human trafficking violations in its own operations and its supply chain. We have zero-tolerance towards slavery and require our supply chain to comply with our values.
This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31December 2022.
‘Projective Group’ is the branding used when referring to all companies owned by the privately owned company Projective Holding NV, a company registered at De Kleetlaan 5A bus 4 1831 Diegem, Belgium. The companies trading within Projective Group have business operations in Belgium, France, Germany, the Netherlands, Switzerland and the United Kingdom.
For more information about our business, please visit our website: www.projectivegroup.com
We operate in the Management Consulting sector. Our clients are predominantly financial services providers, and from time to time we also serve clients in the technology and utilities sectors.
Our supply chain is as follows: We work with a number of key direct suppliers, who provide us with goods (including premises, office equipment and IT hardware), and services (such as outsourced business processes, office cleaning and maintenance, IT software and marketing services).
Notwithstanding these findings, we are committed to continual improvement in managing human rights and modern slavery risk in our business operations and supply chain and we review our policies and procedures and assess the risks within our business and supply chains regularly.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include the following:
We do not tolerate slavery and human trafficking in our supply chains. We employ a risk-based approach to conduct due diligence and supplier audits of our supply chain which is proportional to the scale and scope of our business. Our approach focuses on suppliers with a potentially heightened risk profile of human trafficking or slavery.
Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Where there is evidence or doubt of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following supplier due diligence procedures:
Training on this policy and on the risk our business faces from modern slavery in its supply chains forms part of the induction process for all individuals responsible for supplier purchasing decisions. We require these staff to complete training and ongoing refresher courses on slavery and human trafficking. Our training covers:
We will use Key Performance Indicators (KPIs) to measure our effectiveness of this policy. Our primary KPIs are as follows:
This statement has been approved by the Projective Group’s Board of Directors, who will review and update it annually.
Stefan Dierckx, CEO Projective Group
Policy Name: Modern Slavery and Human Trafficking Statement
Policy Owner: Koen Ermgodts
Key Contacts: Koen Ermgodts, Will Thomas
Policy Version: 1.1
Approved by: Stefan Dierckx, Koen De Smet, Laurent Zintz, Koen Ermgodts
Date of approval: June 2023
Next formal review / revision: June 2024
|Office responsible persons||Koen De Smet (BE)|
Jaco Booster (NL)
Will Thomas (UK)
Kersten M. Meyer (DE)
|People Subject Matter Experts||Melanie Jenner||Yes|