Anti Slavery & Human Trafficking Policy
November 2025
Anti Slavery & Human Trafficking Policy
Purpose
The purpose of the company’s policy is to protect all of employee´ human rights, ensure legal compliance for all regions, manage risks, and enhance a company's ethical standing and reputation. It reflects a commitment to operate responsibly in the global marketplace, without exploitations. This policy helps identify potential risks and set out steps for mitigating them.
This policy aligns with ISO 20400 (Sustainable Procurement) and the UN Guiding Principles on Business and Human Rights.
Scope
This policy applies to:
All employees, contractors, suppliers, and business partners within our organization.
All operations and business activities, both in the country of incorporation and internationally.
All subsidiaries, joint ventures, and affiliates where we hold an interest or have operational control.
Definitions:
Slavery: The condition of an individual who is forced to work under threat or coercion, without the ability to leave or escape the situation, effectively having their freedom restricted.
Human Trafficking: The illegal trade of humans, typically for the purposes of forced labor, sexual exploitation, or other forms of modern slavery. It involves recruiting, transporting, or harboring individuals through force, fraud, or coercion.
Forced Labor: Any work or service that is exacted from an individual under threat or coercion, and that the person has not voluntarily agreed to perform.
Child Labor: The employment of children under the age legally permitted to work, or the exploitation of children through work that harms their physical, mental, or emotional development.
Anti Bribery: preventing individuals or entities from offering, receiving, or soliciting bribes in exchange for favors, decisions, or actions that benefit one party at the expense of another.
Anti Trafficking: Illegal trade of humans for the purpose of exploitation, through force, fraud, or coercion. It is a grave violation of human rights.
Company´s commitment
Our organization is committed to eliminating slavery and human trafficking from our services. We expect the same commitment from all suppliers, contractors, and business partners. This policy reflects our ethical commitment to ensuring safe, fair, and respectful working conditions for all individuals involved in our business.
Jellyfish´s policies work to identify and prevent any sort of slavery and human trafficking within its operations. Jellyfish works to maintain high professional and ethical standards and ensures its employees know their role in maintaining these.
All employees are provided with a written contract of employment and are governed by stringent company policies available on the company intranet.
We do not tolerate any form of modern slavery or human trafficking in any part of our business.
Quantitative Targets & Key Performance Indicators (KPIs)
To ensure the effectiveness of this policy, we will establish and track the following KPI:
- Number of reported incidents or suspected violations of this policy
- Time to investigate and resolve reported cases
- % of employees trained on modern slavery and human trafficking risks
- Training completion rate within onboarding period
KPIs will be reviewed regularly to ensure continuous improvement and accountability.
Training
This policy will be available to all staff and is compulsory to be reviewed for those involved in recruiting and sourcing/managing a supply chain so that they are able to identify risk factors, understand the implications and assist us with implementing the requirements of the Act effectively.
This Policy will be publicly available on Jellyfish’s corporate website to ensure transparency and accountability to our clients, suppliers, investors, and the wider public.
Responsibilities
Leadership team: ensuring the effectiveness of this policy and for overseeing its implementation.
Line Managers: at all levels are responsible for ensuring their teams are aware of the policy, the potential risks of human trafficking and slavery, and the procedure for reporting concerns.
Employees: All employees are responsible for ensuring they follow the standards and procedures outlined in this policy, including reporting any suspicion or knowledge of violations.
Supplier Due Diligence
Jellyfish conducts proportionate and risk-based due diligence on suppliers, contractors, and business partners to identify, assess, and mitigate the risk of modern slavery and human trafficking within our supply chain.
Our due diligence process includes:
• Pre-qualification screening for ethical, labour, and human rights compliance;
• Review of relevant certifications, audit reports, and labour practices; and
• Contractual obligations requiring adherence to this policy and applicable laws.
High-risk suppliers may be subject to enhanced due diligence, including independent audits and corrective-action monitoring. Jellyfish reserves the right to suspend or terminate relationships with suppliers who fail to meet our standards.
Compliance
We are committed to complying with all applicable laws and regulations concerning slavery and human trafficking, including the Modern Slavery Act 2015 and any local legislation in the regions where we operate. We expect all our partners, suppliers, and contractors to adhere to these same principles.
Monitoring and Review Mechanism
Jellyfish will review and update this policy annually to ensure continued alignment with legal requirements, international human rights standards, and best practice frameworks such as EcoVadis, the UN Global Compact, and the ILO Conventions.
Remediation and Corrective Action
If an instance of modern slavery, forced labour, or human trafficking is identified within our operations or supply chain, Jellyfish will take immediate and proportionate action to protect affected individuals and prevent recurrence.
Our remediation approach may include:
• Immediate cessation of exploitative practices;
• Collaboration with relevant authorities, NGOs, or expert organisations to ensure victim protection and support;
• Development and monitoring of corrective-action plans with the supplier; and
• Termination of contracts if the supplier fails to implement adequate remedial measures.
We are committed to acting transparently and responsibly, prioritising the well-being and safety of individuals impacted by any breach.
Reporting & Whistleblowing
Employees and external parties are encouraged to report any concerns, suspicions, or incidents of human trafficking or slavery they encounter.
Reports can be made anonymously if desired, and will be treated with confidentiality. All reports will be thoroughly investigated and acted upon as appropriate. Retaliation against anyone who reports in good faith will not be tolerated.
Approval and implementation
This policy has been approved by the senior leadership team at Jellyfish and is implemented by the People team in collaboration with the Regional Partners. Any changes to the policy will be communicated to all employees and any updates will be reflected in the company´s internal resources.