Modern Slavery and Human Trafficking Statement

JSS Search Limited (T/A The JSS Group) | Financial year ended 31 December 2025

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps taken by JSS Search Limited and its subsidiary undertakings during the financial year ended 31 December 2025 to prevent modern slavery and human trafficking in our business and our supply chains. It is structured against the six areas identified at section 54(5) of the Act.

1. Our structure, our business and our supply chains

JSS Search Limited (company number 08807205) is a recruitment business incorporated in England and Wales, with its registered office at 3 More London Riverside, London SE1 2RE. It is the parent company of the JSS Group, and this statement is made on behalf of JSS Search Limited and its subsidiary undertakings.

We supply permanent, executive search, interim and temporary staff to corporate and public sector clients across professional disciplines, including finance, technology, procurement, human resources and transformation. We operate principally in the United Kingdom, with a smaller volume of European and international assignments. Our own staff are engaged directly on our payroll.

Our supply chain has two parts:

• Workers we supply to clients. Temporary and contract workers are engaged through an umbrella employment provider drawn from our approved list, every one of which holds SafeRec certification. We do not supply workers to clients on our own payroll. Permanent candidates are employed directly by the client on placement.
• Suppliers to our own operations. These comprise umbrella and payroll providers, pre-employment screening providers, second tier recruitment suppliers, outsourced information technology and business support services, and professional services and software providers.

2. Our policies in relation to slavery and human trafficking

We have a zero tolerance approach to modern slavery, forced labour, human trafficking and worker exploitation, and we expect the same standard from our clients, suppliers and partners.

The following policies give effect to that position:

• Modern Slavery Policy
• Whistleblowing Policy
• Anti-Bribery and Corruption Policy
• Conflict of Interest Policy
• Diversity, Equity and Inclusion Policy
• Disciplinary and Capability Procedure, and Grievance Procedure
• Information Security and Data Protection Policy
• Terms of Business and supplier terms and conditions

Policies are owned by the Operations and Compliance function, approved at board level and reviewed periodically.

3. Our due diligence processes

Before a worker is placed

We verify the identity and right to work of every worker we place or engage. Evidence must be current and in the same name as the offer of employment or assignment, and must be recorded before the placement is approved. A placement is not approved where that evidence is absent, expired or inconsistent.

Additional checks, including criminal record, sanctions and adverse media, employment history and qualification verification, are applied where the role or the client requires them. Identity and qualification records are retained and available for inspection in accordance with the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

Contractual position

Signed terms of business are in place with the client before a placement is made. Our terms of business and supplier terms require compliance with the Modern Slavery Act 2015 and with applicable labour, immigration and employment legislation.

How workers are paid

Every temporary and contract worker we supply is paid through a provider on our approved umbrella and payroll list. We maintain that list through a preferred supplier arrangement and do not make payments to intermediaries outside it.

Because all worker pay runs through that list, and because every provider on it holds SafeRec certification, our assurance over worker pay covers the whole of the supplied workforce rather than a sample of it.

Under that certification, their contracts, processes and policies are independently reviewed by a regulated law firm, and every payslip is audited in real time at source and cross-referenced against Real Time Information submissions to HM Revenue and Customs.

This gives us continuous independent evidence that workers in our supply chain are paid correctly and that statutory deductions are calculated, reported and paid, rather than a point in time assurance.

Placement approval

The end to end placement approval process is documented, including the circumstances in which a placement is held or rejected, so that compliance and contractual gaps are identified at a defined control point.

Raising concerns

Staff, workers, candidates and suppliers can raise concerns confidentially through our whistleblowing channel. Any report indicating modern slavery is escalated the same day to the Executive Director responsible and, where appropriate, referred to the Modern Slavery Helpline, the Gangmasters and Labour Abuse Authority or the police.

4. Where the risk sits, and the steps we have taken to assess and manage it

We assess risk by reference to worker type, sector, pay level, geography and the length of the supply chain. Our assessment is as follows:

Steps taken to assess and manage that risk

• Completed a review of our umbrella and payroll intermediaries and confirmed an approved provider list, with payment to providers outside that list not permitted.
• Adopted SafeRec certified providers, giving independent legal due diligence on each provider and real time payslip auditing cross-referenced to HMRC records for workers paid through them.
• Maintained a preferred supplier list, so that supplier relationships are held against a single record rather than managed case by case.
• Documented the placement approval process end to end, with defined hold and reject positions where compliance evidence or contractual terms do not stand up.
• Confirmed that signed terms of business are in place before a placement is made.
• Named an Operations and Compliance Lead with responsibility for this statement, for the indicators below and for the escalation of any concern raised.

5. Our effectiveness, measured against performance indicators

We monitor the following indicators, which we consider appropriate to the size and nature of our business:

We recognise that a nil return against the final indicator is not by itself evidence that our controls are effective, and we read it alongside the coverage measures above it.

6. Training and capacity building

Staff are made aware of modern slavery risk, the indicators of worker exploitation and the escalation route, with additional briefing for those involved in temporary and contract supply, compliance, payroll and supplier management. Staff are told that they are not expected to determine whether an offence has occurred before raising a concern.

During the coming year we will introduce screening of worker records for duplicate bank account, address and contact details, which is a recognised indicator of labour exploitation, by 31 December 2026.

Approval

This statement was approved by the Board of Directors of JSS Search Limited on 21 September 2026 and is signed on its behalf.

Scott Beckson
Director, JSS Search Limited (T/A The JSS Group)
21 September 2026