MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Introduction

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.

Organisation structure, activities and risk assessments

‘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.

  • We believe that the nature of the services which we provide, the locations from which we provide them, and our business practices means that the risk of human trafficking or slavery occurring in our business is low.

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).

  • We believe that the nature of the goods and services which we procure, the locations from which we procure them, and our procurement practices means that the risk of human trafficking or slavery occurring in our supply chains is low.
  • However, we do recognize that some of our procured goods and services may have a heightened risk profile to other services we procure (in particular office cleaning and maintenance services, and fleet services providers).

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.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include the following:

  • Supplier Code of Conduct: Our zero-tolerance approach to modern slaverymust be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
  • Recruitment and Selection Policy: Our Employee Handbook clearly outlines our recruitment and selection process and equal opportunities policy. Our process endeavours through appropriate training to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or subconsciously, in making these decisions.
  • Whistleblowing Policy: Our Employee Handbook clearly outlines the confidential process for employees, customers or suppliers to raise concerns or observations with regard to modern slavery and human traffickingwithin our business operations or supply chain.
  • Employee Code of Conduct: Our Employee Code of Conduct makes clear that we expect all employees to maintain the highest standards of employee and ethical conductwhen representing Projective Group, including when working forourclients, operating abroad and managing oursupply chain.

Supplier Due Diligence

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:

  • Internal supplier audits of suppliers with a heightened risk profile of human trafficking or slavery
  • Due diligence of new suppliers with a heightened risk profile of human trafficking or slavery

Staff training

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:

  • The basic principles and definitions behind the Modern Slavery Act 2015•How to identify the signs of slavery and human trafficking
  • What employees can do to escalate potential slavery or human trafficking issues to the relevant parties within the business
  • What external help is available, for example through the Modern Slavery Helpline
  • What steps we should take if suppliers in our supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chain.

Effectiveness

We will use Key Performance Indicators (KPIs) to measure our effectiveness of this policy. Our primary KPIs are as follows:

  • # of suppliers identified with apotentiallyheightened risk profile of human trafficking or slavery
  • # of suppliers identified with a potentially heightened risk profile of human trafficking or slavery contacted to enquire about their modern slavery practicesin the last 24 months

Board approval

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

Date: 7/13/2023

Reference Information

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

Policy reviewers

RoleNameReview complete
CEOStefan DierckxYes
CPOKoen ErmgodtsYes
CFOLaurent ZintzYes
Office responsible personsKoen De Smet (BE)
Jaco Booster (NL)
Will Thomas (UK)
Kersten M. Meyer (DE)		Yes
People Subject Matter ExpertsMelanie JennerYes