1. Policy Statement

1.1 JL Academy is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers, contractors, and other business partners.

1.2 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

1.3 JL Academy has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

2. Scope of the Policy

2.1 This policy applies to all persons working for JL Academy or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

3. Compliance with the Policy

3.1 All individuals and entities covered by section 2 must ensure they read, understand, and comply with this policy.

3.2 The prevention, detection, and reporting of modern slavery in any part of our business or supply chains are the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3 You must notify your manager or a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

3.6 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or a Director.

3.7 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

4. Our Business and Supply Chains

4.1 JL Academy operates as a provider of professional training services within the United Kingdom.

4.2 Our supply chains primarily include:

* Associate trainers or specialist delivery partners.

* Venue hire for training courses.

* Suppliers of IT equipment and services.

* Providers of marketing and advertising services.

* Suppliers of office equipment and consumables.

* Professional services (e.g., accountancy, legal).

4.3 We recognise that certain areas may pose a higher risk, particularly where services involve lower-skilled labour (e.g., cleaning or catering at hired venues) or where suppliers operate internationally.

5. Due Diligence Processes for Slavery and Human Trafficking

5.1 As part of our initiative to identify and mitigate risk, we undertake due diligence when considering taking on new suppliers and regularly review our existing suppliers. Our due diligence includes:

* Evaluating the modern slavery and human trafficking risks of each new supplier.

* Where appropriate, conducting supplier audits or assessments.

* Including clauses in supplier contracts requiring compliance with the Modern Slavery Act 2015 and this policy.

* Taking steps to improve substandard suppliers’ practices, including providing advice and requiring them to implement action plans.

* Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

6. Responsibility for the Policy

6.1 The Directors of JL Academy have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

6.2 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

7. Training and Awareness

7.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary.

7.2 Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

8. Reporting Concerns (Whistleblowing)

8.1 Employees, suppliers, or other stakeholders who have concerns regarding modern slavery can report them confidentially to a Director of JL Academy via concerns@jl-academy.com

8.2 Reports will be investigated thoroughly, and appropriate remedial action will be taken. JL Academy is committed to protecting whistleblowers from any detrimental treatment.

9. Monitoring and Review

9.1 The effectiveness of the steps we are taking to ensure that slavery and human trafficking is not taking place in our business or supply chains will be kept under periodic review.

9.2 This policy will be reviewed by the Directors at least annually and updated as necessary.

10. Breach of the Policy

10.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

10.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Date of Policy Approval: 24th April 2025

Next Review Date: 24th April 2026