The Cumming Management Group, Inc. Anti-Modern Slavery Statement

Introduction

Certain laws in jurisdictions where The Cumming Management Group, Inc. and its affiliates and subsidiaries, together the (“Cumming Group”) operate require businesses to state actions taken during the financial year to ensure modern slavery is not taking place in their business operations and supply chains.

This statement sets out the steps taken by Cumming Group to prevent modern slavery and human trafficking within its organization and supply chains.

Business Structure

Cumming Group is an international project management and cost consulting firm with a focus on construction in the education, healthcare, themed entertainment, technology, infrastructure, pharmaceutical and hospitality sectors.

Our Supply Chains

We expect all our contractors, suppliers and other business partners to adopt the same high standard as we do to prevent modern slavery, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment. Our procurement process includes vetting of all potential suppliers, with responses being evaluated on the basis of supplier policies and controls. We expect our suppliers to adopt the same principles when contracting with their own suppliers and plan to make this a requirement in 2025.

Our supply chains include: consultants, marketing & PR, recruitment; IT and software services; HR systems, and merchandise suppliers.

Cumming Group considers that the provision of these services and particular supply chains generally present a low risk of modern slavery and human trafficking.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-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.

Additionally, we adopt the following policies which also contribute to the identification of modern slavery risks and prevention of slavery and human trafficking in Cumming Group’s operations, in the following ways:

Whistleblowing policy – We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organization. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Code of conduct – The Cumming Group’s code makes clear to employees the actions and behavior expected of them when representing the organization. The organization strives to maintain the highest standards of employee conduct and ethical behavior when operating abroad and managing its supply chain.
Supplier Code of Conduct Policy – this policy includes specific procedures relating to how slavery and human trafficking risks are identified and assessed through the Firm’s procurement processes.

We have a cross departmental team who work on various compliance matters which consists of involvement from the following departments:

Audit, finance and legal.

Information Technology.
Human Resources.

Recruitment, Training and Work Culture at Cumming Group

We are dedicated to maintaining a fair and ethical workplace for all our staff. The organization uses only specified, reputable employment agencies to source labor and verifies the practices of any new agency it is using before accepting workers from that agency. Our Whistleblowing Policy enables concerns to be raised and resolved. Those can include any concerns about supplier practices.

It is important to us that our colleagues are aware of the issues surrounding modern slavery and support the firm’s values. We therefore intend to offer a training program for existing employees and personnel to reinforce our zero-tolerance policy and the steps to be taken in the event of any concerns within the coming financial year.

Due Diligence Processes for Slavery and Human Trafficking

We assess risk related to human trafficking and slavery associated with our supply base but we are continuing to improve our process for doing so. We intend to implement our Supplier Code of Conduct and require all Suppliers to comply with this policy.

As part of our initiative to identify and mitigate risk we carry out due diligence on our suppliers in an effort to ensure that they comply with slavery and human trafficking legislation, and we provide them with our Anti-Modern Slavery Policy.

Supplier Adherence to Our Values

We have a zero tolerance to slavery and human trafficking. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labor. Cumming Group works with suppliers to ensure that they meet the standards of the Cumming Group Supplier Code of Conduct policy and improve working conditions. However, serious violations of this will lead to the termination of the business relationship.

Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we ensure our staff are aware of our obligations to prevent slavery and human trafficking through the publication of this statement, the availability of the policies referred to within it and through a training program to be introduced in the coming financial year.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes The Cumming Management Group’s slavery and human trafficking statement for the financial year ending 31st December 2024.

CUMMING MANAGEMENT GROUP, INC.

A. Al Jajeh