Anti-Slavery Policy

1. Zero-tolerance commitment

Elite Consulting Club operates a zero-tolerance approach to modern slavery, human trafficking, forced or compulsory labour, servitude, bonded or child labour, and any other form of human exploitation. We do not tolerate such practices in any part of our business or in the businesses of those we work with.

We are committed to acting ethically and with integrity in all of our dealings, and to implementing and enforcing effective systems and controls designed to ensure that modern slavery is not taking place anywhere in our own operations or in our supply chain.

2. Scope of this Statement

This Statement applies to all persons working for us or on our behalf in any capacity, including employees, contractors, consultants, associates, agents, introducers and any other third parties who provide services to or on behalf of Elite Consulting Club.

It covers both our own business and our supply chain and third-party providers, including but not limited to:

• technology, hosting, payment and infrastructure providers who support our platform and services;
• professional advisers, sub-contractors and outsourced service providers;
• partners, affiliates, introducers and referral sources; and
• any other supplier or counterparty engaged in the delivery of our services.

3. Our legal and ethical commitment

We are committed to complying with all applicable anti-slavery, anti-human-trafficking and forced-labour laws in the jurisdictions in which we operate. In particular, we conduct our business in a manner consistent with the spirit and principles of:

• UAE Federal Law No. 51 of 2006 on Combating Human Trafficking Crimes (as amended), which criminalises human trafficking and related exploitation in the United Arab Emirates; and
• the UK Modern Slavery Act 2015, whose principles on transparency, due diligence and the prevention of slavery and human trafficking in business and supply chains we voluntarily seek to uphold as a matter of good practice.

Where other anti-slavery, labour-protection or human-rights laws apply to our activities or those of our counterparties, we expect those standards to be met in addition to, and not in substitution for, the commitments set out in this Statement.

4. Due diligence and supplier expectations

We seek to identify and mitigate the risk of modern slavery through proportionate risk-based due diligence on our suppliers, partners and other third parties before and during our engagement with them.

What we expect from suppliers and partners

We expect every supplier, partner and counterparty to uphold the same standards we set for ourselves. In particular, we expect them to:

• comply with all applicable anti-slavery, anti-trafficking, forced-labour and employment laws;
• ensure that workers are engaged freely, are of legal working age, and are not subject to forced, bonded, indentured or involuntary labour;
• not withhold identity documents, wages or unlawful deposits as a means of control;
• maintain safe and lawful working conditions and pay at least the applicable minimum wage; and
• hold their own suppliers and sub-contractors to equivalent standards throughout the chain.

We reserve the right to audit and to request information, records and reasonable assurances from any supplier or partner in order to verify compliance with this Statement, and to terminate any relationship, agreement or engagement, without liability, where a breach of these expectations is identified or reasonably suspected and not remedied to our satisfaction.

5. Link to KYC and AML controls

Our client and counterparty onboarding is supported by Know Your Customer (KYC) and Anti-Money Laundering (AML) checks. These controls are designed to verify identity, understand the nature of the relationship and detect illicit activity.

Human trafficking and modern slavery are frequently connected to money laundering and other financial crime. Our KYC and AML procedures therefore form part of our wider control framework and help us to identify red flags that may indicate exploitation, and to decline, escalate or report suspicious activity as appropriate.

6. Reporting concerns (whistleblowing)

We encourage anyone with knowledge or a reasonable suspicion of modern slavery, human trafficking or forced labour connected to our business or supply chain to raise it with us promptly. Reports may be made in confidence and, where permitted by law, anonymously.

Concerns can be reported to us by email at [email protected] or by telephone at +971 502733997 (Monday to Friday, 9:00–18:00 GST). We will not tolerate any retaliation, dismissal, disciplinary action or detrimental treatment against any person who raises a concern in good faith.

Where there is an immediate risk to a person’s safety, contact the local emergency or law-enforcement authorities without delay.

7. Training and awareness

We provide our personnel with appropriate information and awareness so that they can understand the risks of modern slavery and human trafficking, recognise the warning signs, and know how to escalate concerns. We keep our controls and this Statement under review and update our training as our business and its risk profile evolve.

8. Enforcement and consequences of breach

Compliance with this Statement is mandatory. Any breach will be taken seriously and may result in consequences appropriate to the circumstances, including:

• for personnel: disciplinary action, up to and including termination of employment or engagement;
• for suppliers, partners and counterparties: suspension or termination of the relationship, contract or engagement, without liability to us, and the withdrawal of any access to our services or platform;
• the exercise of our audit and information rights to investigate the suspected breach; and
• reporting to the relevant authorities, including law-enforcement and regulatory bodies, where we identify or reasonably suspect modern slavery, human trafficking or forced labour.

Nothing in this Statement limits any right or remedy available to us under the relevant contract or at law.

9. Supplier and partner contractual obligations

Where we engage suppliers, introducers, partners, agents or other counterparties, we expect the commitments in this Statement to be reflected in our contractual arrangements with them. In particular, each supplier, introducer and partner is required to:

• comply with all applicable anti-slavery, anti-human-trafficking and labour laws in every jurisdiction relevant to its performance;
• flow down equivalent obligations to its own suppliers, sub-contractors and agents throughout its supply chain;
• notify us promptly of any actual or suspected breach of such laws, or of this Statement, connected to its business or supply chain; and
• cooperate in good faith with any audit, inquiry or investigation we conduct in relation to these obligations.

We may, at any time and acting reasonably, request certifications, self-declarations and supporting evidence of compliance from any supplier, introducer or partner, and may make continuation of the relationship conditional on receiving them.

A breach of these obligations is treated as a material breach entitling us to terminate the relevant relationship, contract or engagement with immediate effect, without liability, penalty or compensation owed by us, and without prejudice to any other right or remedy available to us under the contract or at law.

10. Remediation

Where a concern raised under this Statement is investigated and substantiated, we will respond in a manner proportionate to the nature, severity and circumstances of the issue. Depending on the case, our response may include:

• requiring the counterparty to implement a corrective-action plan within a defined timeframe;
• applying enhanced monitoring, additional reporting or further due diligence to the relationship;
• suspending the relationship, engagement or access to our services pending remediation;
• terminating the relationship, contract or engagement in accordance with section 9; and
• reporting the matter to the relevant authorities, including law-enforcement and regulatory bodies, where required or appropriate.

Where appropriate and reasonably practicable, we will also consider what support can be provided or facilitated for persons affected by the conduct in question, including signposting to competent authorities and support organisations.

11. Annual review and continuous improvement

This Statement is reviewed at least annually, and additionally whenever there is a material change to our business, our supply chain, our risk profile or the applicable legal framework. Our management is responsible for approving this Statement and for overseeing its implementation across the business.

As part of our commitment to continuous improvement, we may track indicators of the effectiveness of our approach, which may include:

• the coverage of due diligence performed on suppliers, partners and other counterparties;
• the completion of training and awareness activities by relevant personnel; and
• the number and nature of concerns raised and resolved under this Statement.

12. No third-party rights; relationship to Terms

This Statement is a policy declaration made in good faith. It describes our approach and aspirations; it does not create contractual obligations, nor confer enforceable rights, on any third party, and it does not constitute a warranty, representation or undertaking for the benefit of any person, whether a client, supplier, partner or otherwise.

This Statement must be read together with our Terms & Conditions and our AML & KYC Policy. In the event of any conflict or inconsistency between this Statement and those documents, the Terms & Conditions and the AML & KYC Policy shall prevail.

To the maximum extent permitted by applicable law, no liability of any kind arises from this Statement itself, from any statement of intent it contains, or from any act or omission in connection with its implementation.

13. Governing law and interpretation

This Statement is governed by the laws of the United Arab Emirates, and any dispute arising out of or in connection with it is subject to the exclusive jurisdiction of the courts of Dubai, in accordance with our Terms. The English language version of this Statement is the governing version.

We keep this Statement under regular review and may update it from time to time to reflect changes in our business, our supply chain or applicable law.

14. How to contact us

Questions about this Statement, or reports of concern, can be directed to Elite Consulting FZC-LLC using the details below: