Anti-Modern Slavery Policy

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.

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

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.

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.

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.

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.
• 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.

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

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

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