Modern Slavery & Human Trafficking Policy

1. Policy statement

Project Business Solutions Ltd is committed to acting ethically and with integrity in our business dealings and relationships. We recognise that modern slavery and human trafficking are serious crimes and violations of human rights, and we take a zero-tolerance approach to modern slavery and human trafficking within our operations where reasonably practicable.

This policy sets out the steps we take, proportionate to the size and nature of our business, to minimise the risk of modern slavery and human trafficking.

2. Scope

This policy applies to:

• All employees, directors, contractors, and agency workers

• All suppliers and third-party partners engaged by Project Business Solutions Ltd

3. Our business & supply chain

Project Business Solutions Ltd is a UK-based SME operating as a broker and provider of mobile, VoIP, energy, and broadband services to businesses and organisations across the UK.

Our supply chain is relatively limited and primarily consists of:

• UK-based service providers

• Established suppliers of telecoms, IT, and business services

We do not operate in high-risk sectors such as manufacturing, agriculture, or overseas labour-intensive industries.

4. Risk assessment

Given the nature and scale of our operations, we assess the risk of modern slavery within our direct business activities as low, based on current operations.

We acknowledge that some risk may exist within wider supply chains. To address this proportionately, we:

• Prefer to work with reputable suppliers

• Avoid engaging suppliers where we have reasonable grounds for concern

• Expect suppliers to comply with applicable employment and human rights laws

We do not conduct formal audits of suppliers but will review concerns if they are raised.

5. Due diligence & supplier expectations

As an SME, our approach to due diligence is pragmatic and proportionate. We:

• Seek to work with suppliers who demonstrate ethical business practices

• May request confirmation that suppliers comply with relevant employment and labour laws

• Reserve the right to terminate relationships where serious concerns are identified

6. Reporting concerns

Employees and contractors are encouraged to raise concerns relating to modern slavery or human trafficking if they become aware of potential issues.

Concerns can be raised with:

• A line manager

• A director of the business

All reports will be treated seriously and, where appropriate, investigated. Reports will be handled sensitively and, where possible, confidentially.

7. Training & awareness

Due to the size and risk profile of the business, we do not currently provide formal modern slavery training. However, senior staff are expected to remain aware of relevant risks and ensure ethical standards are upheld.

This approach will be reviewed if the nature or scale of the business changes.

8. Responsibility

Overall responsibility for this policy sits with the directors of Project Business Solutions Ltd, who are responsible for reviewing its effectiveness and ensuring it remains appropriate.

9. Review

This policy will be reviewed annually or sooner if:

• The business grows significantly

• Our supply chain changes materially

• Legal or regulatory requirements change