JCR Group Ltd (trading as Bodyswaps) MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2023

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities for the financial year ending 31 August 2023.

JCR Group Ltd (trading as Bodyswaps) ('the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational structure

JCR Group Ltd (trading as Bodyswaps) has business operations in the United Kingdom and the United States of America (trading as Bodyswaps US, Inc). Bodyswaps US, Inc is a fully owned subsidiary of JCR Group Ltd. (registered in the UK). JCR Group Ltd. is an independent company.

We operate in the software development sector. Bodyswaps is a soft skills training solution offering a library of VR and mobile simulations for various topics such as employability, communication skills, public speaking, healthcare, leadership and more.

The nature of our supply chain includes working with third-party partners. Bodyswaps like most modern SaaS platforms uses third party sub processors to host our code and databases. This enables us to scale efficiently and offer best in class redundancy and security. The majority of technology stack is built on top of Google Services with additional services operated by Microsoft, Mongo and Open AI. We reserve the right to change our service providers in future and will notify customers of any changes.

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include the following:

  • Staff handbook - Equal Opportunities Statement - We are committed to the fair treatment of all staff. Our staff handbook and Equal Opportunities statement reflects our zero-tolerance approach to any discrimination or mistreatment of employees.
  • Responsible Business Principles

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

External supplier audits for those we consider to be high-risk.

Our due diligence procedures aim to:

  • Identify and action potential risks in our business and supply chains.
  • Monitor potential risks in our business and supply chains
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
  • Provide protection for whistleblowers.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

  • Evaluating the slavery and human trafficking risks of each new supplier.
  • Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and the European Union and in low-risk industries, such as internet software and services.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.

Next steps

In the next financial year, we intend to introduce new policies and procedures in addition to providing further training and support to our employees to tackle slavery and human trafficking.

The statement was approved by the board of directors:

  • Julien Denoel, COO and Co-Founder of Bodyswaps
  • Thomas Szirtes, CTO and Co-Founder of Bodyswaps
  • Christophe Mallet, CEO and Co-Founder of Bodyswaps