Introduction

This statement applies to Gibbs Consulting Global Limited (referred to in this statement as “the Organisation”). The information included in the statement refers to the financial year 2025.

It is a priority for Gibbs Consulting Global Limited to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our Organisation and in our supply chain.

As a globally diverse, woman owned and ethnic minority-owned business, our employees, candidates, and the resources we supply are the focus of everything we do.

We are taking appropriate measures to ensure that everyone who works for us benefits from a working environment in which their fundamental human rights are respected, and anyone we do business with also upholds these principles.

Definitions

The Organisation considers that modern slavery encompasses:

• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse or the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, Europe, Middle East & Africa, and US.

Organisation’s structure

We are a global provider of IT & Business Services providing programme consultancy, strategic resourcing and talent services in Technology, Regulatory, Infrastructure, Development, Architecture, Business & Technology Change and Operations. Supporting clients across Financial Services, Banking, Technology and FMCG.

We are a part of the Atrium Group of companies (Group). The Group, operated by its board of directors, has over six thousand employees worldwide and operates across the UK, Europe, the Middle East & Africa, and the US. Our business is organised into business units: Programme Consultancy,Talent Services and Workforce Solutions.

Our supply chains

In order to fulfil its activities, the main supply chains of the Organisation include those related to companies, individuals and consultants that provide the services and goods that enable us to operate our business.

Our policies on slavery and human trafficking

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

As part of our initiatives to identify and mitigate the risk of modern slavery and human trafficking, we have a robust supply chain compliance programme, and all suppliers are subject to due diligence and strict compliance checks to ensure compliance with statutory requirements and industry sector best practice.

Due diligence is also undertaken on all candidates, and this includes (but is not limited to) identity verification and right to work checks.

We also have systems in place to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain comply with our values, ethics, policies, statutory requirements, and industry sector best practice, these are incorporated into all our agreements with suppliers as contractual obligation.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide regular training to our staff.

Key Performance Indicators/Steps

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

• Review modern slavery risks in our supply chain.
• Incorporate modern slavery training into our annual employee training schedule.
• Improve supplier awareness of our modern slavery policies and procedures by including and sharing our modern slavery statement when engaging clients and suppliers.
• Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
• Any actions taken to embed a zero-tolerance policy towards modern slavery

Modern slavery compliance officer

The Organisation has a modern slavery compliance officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of s.54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Farida Gibbs, President, June 2025