Modern Slavery & Human Rights

1. Our Commitment

PMG is unequivocally committed to upholding and promoting fundamental human rights and combating all forms of modern slavery, including forced labour, child labour, human trafficking, and servitude, within our operations and supply chain. We believe that every individual has the right to fair treatment, dignity, and a safe working environment.
PMG has zero tolerance for modern slavery, human trafficking, forced or compulsory labour, and child labour. We are committed to identifying and mitigating risks related to these practices in all parts of our operations and extended value chains, reflecting our values and legal obligations under relevant legislation.

2. Scope of Application

This policy applies to:

• All PMG employees, consultants, and contractors
• Third-party vendors, suppliers, and service providers
• Joint ventures, project partners, and subcontractors
• Any party conducting work on behalf of PMG

3. Due Diligence & Risk Management

PMG undertakes risk assessments and due diligence processes when onboarding suppliers, partners, and subcontractors. These include:

• Evaluating supplier adherence to labour laws and ethical sourcing practices
• Requiring contractual affirmations of compliance with anti-slavery laws
• Conducting periodic reviews where risk factors (e.g., geography, sector, subcontracting layers) are present

3.1 Risk Assessment and Mitigation

Based on our due diligence, PMG identifies and manages risks as follows:

• Risk Identification: We proactively identify potential modern slavery and human rights risks across our operations and supply chains, considering factors such as geographic location, industry sector, nature of goods/services, and labor intensity.
• Risk Evaluation: Identified risks are evaluated based on their likelihood and potential impact.
• Mitigation Strategies: For any identified risks, PMG implements appropriate mitigation strategies. This may involve engaging with suppliers to understand and improve their practices, requesting evidence of their due diligence, prioritizing reputable suppliers with strong ethical commitments, or, if necessary, re-evaluating or terminating relationships with non-compliant parties.
• Continuous Monitoring: We continuously monitor our operations and supply chains for emerging risks and the effectiveness of our mitigation measures.

4. Training and Capacity Building

To ensure a high level of understanding of modern slavery risks and human rights principles, PMG provides training to relevant employees:
Key Personnel Training: Employees involved in procurement, human resources, and management receive training on identifying and addressing modern slavery and human rights risks.
General Awareness: All employees are made aware of PMG's commitment to human rights and the importance of reporting any concerns through our internal communication channels and policy documents.

5. Reporting Mechanisms

PMG encourages all employees, suppliers, and other stakeholders to report any concerns related to modern slavery or human rights abuses.

Internal Reporting: Concerns can be reported confidentially through our Whistleblowing Policy, directly to HR, or to the Data Protection Officer (DPO).

Investigation and Action: All reports will be thoroughly investigated. If an instance of modern slavery or human rights abuse is identified, PMG will take immediate and appropriate action, which may include working with the supplier to implement corrective measures, engaging with relevant authorities, and terminating relationships with non-compliant suppliers. Our priority is the safety and well-being of affected individuals.

6. Legal & Regulatory Compliance

PMG is a service-based consulting firm and does not produce, import, export, or distribute goods or raw materials across jurisdictions. As such, PMG is not directly subject to supply chain disclosure requirements that apply to manufacturers, importers, or goods-based commercial entities. However, PMG is fully committed to upholding and complying with all applicable modern slavery and human rights legislation in the jurisdictions where we are registered, operate, or serve clients.

Where applicable, PMG will:

• Ensure internal compliance with jurisdiction-specific legal obligations related to labour standards, ethical procurement, and reporting.
• Support clients in meeting their obligations under regional or international anti-slavery and supply chain transparency laws by offering strategic, legal-adjacent, and operational advisory services.
• Monitor changes in relevant legislation and adapt our internal and client-facing practices accordingly.

6.1 Jurisdiction-Specific Compliance

PMG adheres to or supports compliance with the following regional frameworks:

Canada:	PMG complies with the Fighting Against Forced Labour and Child Labour in Supply Chains Act (S.C. 2023, c. 9), to the extent that its obligations apply to service firms. While PMG is not a goods importer or producer, we assist clients in preparing reports, risk assessments, and governance frameworks that support compliance with the Act. Where required, PMG will file its annual disclosures and make them available in accordance with governing law.
United States:	PMG operates in compliance with H.R.3244 - Victims of Trafficking and Violence Protection Act of 2000 and relevant state-level laws, including the California Transparency in Supply Chains Act, where applicable. PMG does not engage in commercial goods transactions; however, whenever applicable, based on the nature of our clients’ businesses, we advise clients on how to align with federal and state regulations regarding forced labour, particularly in global supply chains or customs enforcement contexts.
European Union:	PMG monitors and aligns its policies with EU directives such as the Directive 2011/36/EU of the European Parliment and of the Council of 5 April 2011 on preventing and combating trafficking in human beings and protecting its victims, and replacing Council Framework Decision 2002/629/JHA on Trafficking in Human Beings, and the proposed Corporate Sustainability Due Diligence Directive (CSDDD). While not directly subject to these regulations, PMG supports EU-based clients with compliance strategy and reporting preparation related to human rights and environmental due diligence.
United Kingdom:	PMG supports the aims of the Modern Slavery Act 2015 and ensures that any required public statements are produced and published in accordance with the law. Although not required to produce a slavery and human trafficking statement under the Act’s current thresholds, PMG proactively maintains internal governance and advises clients who are subject to these obligations.
Australia:	PMG complies with the Modern Slavery Act 2018 (C2024C00747) to the extent it applies to service-oriented businesses and our operations within Australia or with Australian clients. PMG supports clients with annual Modern Slavery Statement preparation, due diligence mapping, and risk remediation planning. Internally, PMG reviews its supplier relationships to identify and address any potential ethical risks.
Philippines	PMG complies with the Labor Code of the Philippines (Presidential Decree No. 442), as amended, the Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003), as expanded by Republic Act No. 10364 (Expanded Anti-Trafficking in Persons Act of 2012), and Republic Act No. 9231 (An Act Providing for the Elimination of the Worst Forms of Child Labor), in each case to the extent such legislation applies to service-based businesses and PMG's specific operations in the Philippines, including those conducted through affiliates or other operating names. PMG's operations in the Philippines, including those conducted through its affiliates, are subject to regular internal compliance reviews. PMG supports clients operating in or sourcing from the Philippines with due diligence mapping, supplier risk assessments, and compliance program development aligned with local labor regulations and ILO conventions ratified by the Philippines.
South Africa	PMG complies with the Basic Conditions of Employment Act, 1997 (Act No. 75 of 1997), the Employment Equity Act, 1998 (Act No. 55 of 1998), and the Prevention and Combating of Trafficking in Persons Act, 2013 (Act No. 7 of 2013), in each case to the extent such legislation applies to service-based businesses and PMG's specific operations in South Africa. PMG further aligns with the Broad-Based Black Economic Empowerment Act, 2003 (Act No. 53 of 2003) and its associated Codes of Good Practice, to the extent applicable to PMG's engagement with South African clients and partners. PMG advises clients with South African operations or supply chains on compliance with the Companies Act, 2008 (Act No. 71 of 2008) and King IV Report on Corporate Governance requirements related to human rights and social and ethics committees.
India	PMG complies with the Bonded Labour System (Abolition) Act, 1976, the Child and Adolescent Labour (Prohibition and Regulation) Act, 1986, and the Immoral Traffic (Prevention) Act, 1956, in each case to the extent such legislation applies to service-based businesses and PMG's specific operations in India. PMG further aligns its operations with the Code on Wages, 2019 and the Occupational Safety, Health and Working Conditions Code, 2020, to the extent applicable to service-based enterprises. PMG advises clients with operations or supply chains in India on compliance with the Companies (Corporate Social Responsibility Policy) Rules, 2014 and evolving human rights due diligence expectations under Indian corporate governance frameworks.
United Arab Emirates (UAE)	PMG complies with Federal Decree-Law No. 33 of 2021 Regarding the Regulation of Labour Relations and Federal Law No. 51 of 2006 on Combating Human Trafficking Crimes, as amended by Federal Law No. 1 of 2015, in each case to the extent such legislation applies to service-based businesses and PMG's specific operations in the UAE. PMG recognizes the unique labor dynamics of the UAE, including the kafala sponsorship system's recent reforms and the distinct compliance landscape across mainland and free zone jurisdictions. PMG supports clients operating in the UAE with human rights due diligence, supplier onboarding protocols, and alignment with the UAE's National Committee to Combat Human Trafficking standards.
Hong Kong SAR	PMG complies with the Employment Ordinance (Cap. 57) and the Crimes Ordinance (Cap. 200), in each case to the extent such legislation applies to service-based businesses and PMG's activities in Hong Kong. While PMG does not currently maintain a dedicated regional office in Hong Kong, PMG serves clients with Hong Kong operations and advises on compliance with local labor standards, supply chain transparency expectations, and alignment with regional anti-trafficking initiatives.
Other Jurisdictions:	In jurisdictions not listed above, PMG follows all local labour and human rights laws where it operates or is legally registered. Where specific legislation is absent, PMG aligns with international frameworks, including the UN Guiding Principles on Business and Human Rights and the International Labour Organization (ILO) Conventions, Protocols and Recommendations.

8. Effectiveness and Future Steps

PMG is committed to continuous improvement in its efforts to combat modern slavery and uphold human rights. We will:

1. Regularly review and update this statement and our related policies to reflect best practices and evolving legal requirements.
2. Monitor the effectiveness of our due diligence processes and training programs.
3. Seek opportunities to collaborate with industry peers and expert organizations to enhance our approach.

9. Approval

This Modern Slavery and Human Rights Statement has been approved on July 14, 2025. It will be reviewed annually and updated as necessary.