Legal & Ethical Business Conduct Policy

Effective date: 27 August 2026

Our commitment

We believe that sustainable business success is built on trust, accountability, transparency and ethical conduct.

As a provider of technology transformation, programme and project management, architecture assurance, crisis management and advisory services, we are committed to conducting all business activities lawfully, ethically and professionally. Our clients trust us to provide independent advice and objective challenge, and we take that responsibility seriously.

Juntos Solutions’ mission is to work alongside clients to deliver successful outcomes whilst building their capability to succeed independently.

Our ethical principles

Integrity first

We are honest, transparent and accountable in all our dealings. We act with integrity even when doing so is difficult or commercially challenging.

We will:

• Always act in the best interests of our clients.
• Be open and honest in our communications.
• Deliver objective advice based on evidence and experience.
• Accept responsibility for our actions and decisions.
• Challenge constructively when we believe risks or concerns may affect outcomes.

Independence

Our advice is independent and vendor agnostic.

We do not promote, recommend or favour technologies, products or services because of commercial incentives. Our recommendations are guided solely by what is right for our clients and their business objectives.

Respect

We treat everyone with dignity, fairness and respect regardless of role, background, experience, nationality, ethnicity, religion, disability, age, gender or personal characteristics.

We expect the same standard of behaviour from our employees, associates, contractors, clients and suppliers.

Compliance with laws and regulations

Juntos Solutions is committed to complying with all applicable laws and regulations governing our business activities.

This includes, but is not limited to:

• UK data protection and privacy legislation.
• Anti-bribery and anti-corruption legislation.
• Modern Slavery Act requirements.
• Employment legislation.
• Health and safety obligations.
• Intellectual property laws.
• Competition and fair trading regulations.

All employees, associates and contractors are expected to understand and comply with relevant legal obligations relating to their work.

Anti-bribery and corruption

Juntos Solutions has a zero-tolerance approach to bribery, corruption and unethical influence.

No employee, associate or representative may:

• Offer, give or accept bribes.
• Provide improper financial or business advantages.
• Use gifts, hospitality or entertainment to influence business decisions improperly.
• Facilitate improper payments of any kind.

All business decisions must be made transparently, ethically and in compliance with applicable laws.

Modern slavery and human rights

Juntos Solutions is committed to protecting human rights and preventing modern slavery, forced labour, child labour and human trafficking in all forms.

We expect our employees, associates, suppliers and business partners to operate to the same standards and to comply with applicable human rights legislation and ethical employment practices.

Confidentiality and data protection

Our clients entrust us with sensitive business information.

We are committed to:

• Protecting confidential information.
• Respecting privacy rights.
• Handling information securely and responsibly.
• Complying with applicable data protection legislation.
• Ensuring information is accessed only by authorised individuals.

Confidential information obtained through client engagements must never be disclosed without appropriate authorisation unless legally required.

Conflicts of interest

We seek to avoid situations where personal, financial or commercial interests could compromise professional judgement.

Employees, associates and contractors must:

• Declare any actual or potential conflicts of interest.
• Avoid relationships or activities that could impair objectivity.
• Immediately disclose circumstances that could create an appearance of bias.

Where conflicts arise, appropriate mitigation measures will be implemented.

Fair business practices

We are committed to competing fairly and professionally.

We will:

• Win business through capability, experience and value.
• Communicate honestly about our services and expertise.
• Respect client, partner and competitor intellectual property.
• Avoid misleading, deceptive or unfair business practices.

Environmental and social responsibility

As part of our commitment to responsible business practices, Juntos Solutions seeks to minimise environmental impact and support sustainable business decisions wherever practical.

We believe organisations have a responsibility to contribute positively to society through ethical behaviour, responsible governance and respect for the communities they serve.

Speaking up

Everyone associated with Juntos Solutions has a responsibility to raise concerns if they become aware of conduct that may be unethical, illegal or inconsistent with this policy.

Examples include:

• Bribery or corruption.
• Fraud or financial misconduct.
• Data protection breaches.
• Modern slavery concerns.
• Discrimination or harassment.
• Conflicts of interest.
• Unethical behaviour.

To raise a concern, contact us at info@juntos-solutions.com.

Concerns will be treated seriously, investigated appropriately and handled confidentially wherever possible.

No individual will suffer retaliation for raising genuine concerns in good faith.

Accountability

Every employee, associate and contractor representing Juntos Solutions is expected to uphold the principles contained within this policy.

Failure to comply with these standards may result in corrective action, termination of engagements or referral to appropriate authorities where required.

Juntos Solutions works alongside its clients to build trust, reduce risk and deliver successful outcomes through ethical leadership, expert execution and unwavering commitment to doing what is right.