Appendix L: The JLT Group Code of Conduct

Introduction

This Code of Conduct outlines the ethical and professional standards expected of all Agents who are members of The JLT Group. By maintaining Membership, Agents agree to uphold these principles in all business activities and interactions.
This Code of Conduct forms an integral part of the Membership Agreement and is legally binding. Violations may result in disciplinary action, including suspension or termination of Membership.

1. Professional Conduct

1.1 Agents must conduct themselves with the highest standards of professionalism, integrity, and honesty in all dealings with clients, suppliers, and The JLT Group.
1.2 Agents must act in the best interests of their clients at all times, providing accurate, transparent, and timely information.
1.3 Agents must not engage in any conduct that could reasonably be expected to damage the reputation or goodwill of The JLT Group.

2. Client-Centric Service

2.1 Agents must prioritise the needs and interests of their clients, ensuring that all services provided are of the highest quality.
2.2 Agents must respond to client enquiries and concerns promptly and professionally.
2.3 Agents must ensure that all client communications are clear, accurate, and compliant with applicable laws and regulations.
2.4 Agents must respect client confidentiality and handle all personal data in accordance with data protection laws.

3. Fraud and Misrepresentation

3.1 The JLT Group maintains a strict zero-tolerance policy for fraud, misrepresentation, or any form of dishonest conduct.
3.2 Agents must not engage in any fraudulent activities, including but not limited to:
3.2.1 Fraud includes, but is not limited to:
3.2.1.1 Misrepresenting travel services, prices, or terms to clients.
3.2.1.2 Falsifying booking records, invoices, or financial documents.
3.2.1.3 Misappropriating client funds or using client funds for unauthorised purposes.
3.2.1.4 Providing false information to The JLT Group, suppliers, or regulatory authorities.
3.2.1.5 Initiation of fraudulent chargebacks for membership fees or other payments after having received the corresponding services.
3.3 Any suspected or actual fraud must be reported to The JLT Group immediately.
3.4 Violations of this section will result in immediate termination of Membership and may lead to legal action and reporting to law enforcement authorities.

4. Financial Integrity

4.1 Agents must handle all financial transactions with the utmost integrity and transparency.
4.2 Agents must ensure that all client payments are processed in accordance with The JLT Group's procedures and applicable regulations.
4.3 Agents must not accept payments directly into personal or business accounts. All client funds must be paid directly into the PTS Trust in accordance with Section 48 of the Membership Agreement.
4.4 Agents must maintain accurate and complete financial records for all transactions.
4.5 Agents must not engage in any activity that could be construed as money laundering, tax evasion, or other financial crimes.

5. Transparency and Honesty

5.1 Agents must provide clients with clear, accurate, and complete information about all aspects of their travel arrangements.
5.2 Agents must disclose all fees, charges, and terms and conditions to clients before confirming bookings.
5.3 Agents must not make false or misleading claims about travel services, destinations, or suppliers.
5.4 Agents must ensure that all marketing materials and communications are truthful and comply with advertising standards.

6. Compliance with Laws and Regulations

6.1 Agents must comply with all applicable laws and regulations, including but not limited to:
6.1.1 The Package Travel and Linked Travel Arrangements Regulations 2018.
6.1.2 ATOL regulations.
6.1.3 UK GDPR and Data Protection Act 2018.
6.1.4 Consumer Rights Act 2015.
6.1.5 Consumer Protection from Unfair Trading Regulations 2008.
6.1.6 Equality Act 2010.
6.1.7 Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
6.2 Agents must stay informed of changes to applicable laws and regulations and ensure ongoing compliance.
6.3 Agents must complete all mandatory training and compliance requirements as specified by The JLT Group.

7. Handling Client Funds

7.1 Agents must handle client funds with the highest level of care and in strict accordance with legal and regulatory requirements.
7.2 All client funds must be paid directly into the PTS Trust account. Agents are strictly prohibited from receiving client funds into personal or business accounts.
7.3 Agents must ensure that all payments are processed through The JLT Group's approved payment methods.
7.4 Agents must not use client funds for any unauthorised purpose.
7.5 Agents must maintain clear and accurate records of all client payments.
7.6 Any irregularities or suspected breaches of client fund handling procedures must be reported to The JLT Group immediately.
7.7 Violations of this section constitute a serious breach of the Membership Agreement and may result in immediate termination, legal action, and reporting to regulatory authorities.
7.8 Agents must ensure that all bookings, including personal bookings, have all applicable bank-related charges and PTS Trust charges covered in full.
7.9 Agents must comply with all PTS Trust requirements as detailed in Appendix I of the Membership Agreement.
7.10 Agents must not misrepresent the status of client funds or provide false information regarding payment processing.

8. Branding and Marketing

8.1 Agents must adhere to The JLT Group's branding and marketing guidelines at all times.
8.2 All marketing materials, advertisements, and promotional content that use The JLT Group's intellectual property or reference The JLT Group must:
8.2.1 Align with The JLT Group's branding guidelines.
8.2.2 Be submitted to for approval prior to use.
8.2.3 The JLT Group will review and approve or reject materials within 5 business days. If no response is received within 10 business days, materials shall be deemed approved.
8.3 Agents must not use The JLT Group's branding, logos, or trademarks in any manner that could damage the reputation or goodwill of The JLT Group.
8.4 Agents must ensure that all marketing activities comply with applicable advertising standards and consumer protection laws.
8.5 Agents must not engage in misleading advertising, including false "from" prices, unavailable offers, or hidden fees.
8.6 Use of unapproved marketing materials may result in disciplinary action, including suspension or termination of Membership.

9. Supplier Relationships

9.1 Agents must maintain professional and respectful relationships with all suppliers.
9.2 Agents must comply with all supplier terms and conditions.
9.3 Agents must not engage in any conduct that could damage The JLT Group's relationships with suppliers.
9.4 Agents must not attempt to establish direct relationships with The JLT Group's preferred suppliers for the purpose of bypassing The JLT Group or obtaining more favourable terms.
9.5 Agents must report any issues or concerns with suppliers to The JLT Group promptly.

10. Data Protection and Privacy

10.1 Agents must comply with all data protection laws, including the UK GDPR and Data Protection Act 2018.
10.2 Agents must handle all personal data securely and only use it for legitimate business purposes.
10.3 Agents must obtain appropriate consent from clients before collecting, processing, or sharing their personal data.
10.4 Agents must implement appropriate security measures to protect personal data from unauthorised access, loss, or disclosure.
10.5 Agents must report any data breaches to The JLT Group immediately and in any event within 24 hours of becoming aware of the breach.
10.6 Agents must respect individuals' data protection rights, including the right to access, rectification, erasure, and objection.
10.7 Agents must not share personal data with unauthorised third parties.
10.8 Agents must ensure that all client contact information is kept up-to-date and accurate in The JLT Group's booking system.

11. Digital Conduct

11.1 Agents must maintain professionalism in all online interactions, including on social media, WhatsApp groups, and other digital platforms.
11.2 Agents must not post or share content that could damage the reputation of The JLT Group or its members.
11.3 Agents must respect the confidentiality of information shared within The JLT Group's WhatsApp community and other private forums.
11.4 Agents must not engage in cyberbullying, harassment, or any form of online misconduct.
11.5 Agents must ensure that all social media posts and online content comply with advertising standards and do not contain false or misleading information.
11.6 Agents must clearly distinguish their personal views from those of The JLT Group when posting on social media.

12. Whistleblowing

12.1 The JLT Group is committed to maintaining the highest standards of ethical conduct and compliance. Agents are encouraged to report any concerns about wrongdoing, misconduct, or violations of this Code of Conduct.
12.2 Whistleblowing refers to the act of reporting suspected or actual unethical behaviour, illegal activities, or violations of Company policies.
12.3 Agents may report concerns through the following channels:
12.3.1 Email:
12.3.2 Written correspondence to the registered office address.
12.3.3 Direct verbal reporting to senior management (by appointment).
12.4 Reports made under this policy will be treated with the highest level of confidentiality.
12.4.1 The identity of the whistleblower will be protected, and no details will be disclosed without their prior consent, except as required by law or to facilitate a thorough investigation.
12.4.2 Agents are permitted to report concerns anonymously if they prefer, although providing contact details may help the Company investigate and resolve the matter more effectively.
12.5 The JLT Group strictly prohibits any form of retaliation, harassment, or victimisation against whistleblowers who report concerns in good faith.
12.5.1 Agents who believe they have faced retaliation should report it immediately through the whistleblowing channels.
12.6 All reports submitted under this policy will be promptly acknowledged, reviewed, and investigated by an impartial member of the compliance team or senior management.
12.6.1 Investigations will be conducted fairly, transparently, and in a timely manner to ensure the resolution of reported issues.
12.6.2 Whistleblowers will be informed of the outcome of the investigation where appropriate and permissible by law.
12.7 While this policy protects whistleblowers who report concerns in good faith, The JLT Group will not tolerate malicious or knowingly false reports. Agents submitting such reports may face disciplinary action.
12.8 The JLT Group views whistleblowing as a constructive tool to uphold ethical standards and improve organisational practices. Feedback from whistleblowing cases will be incorporated into policy reviews and training programs.

13. Substance Abuse

13.1 Agents must not perform business-related duties under the influence of alcohol, illegal substances, or any substance that impairs professional judgment or conduct.

14. Environmental Responsibility

14.1 Agents are encouraged to adopt environmentally sustainable practices, such as minimising paper use and working with suppliers who prioritise sustainability.

15. Conflicts of Interest

15.1 Agents must disclose any conflicts of interest that could potentially impact their duties or The JLT Group's interests.
15.2 Agents must avoid situations that could lead to a conflict between personal and professional interests.

16. Use of Company Resources

16.1 Agents must only use The JLT Group's resources (e.g., branding, marketing materials, and platforms) for authorised business purposes.
16.2 Misuse of these resources may lead to disciplinary action, up to and including termination of Membership.

17. Training and Development

17.1 Agents are required to complete mandatory training and adhere to ongoing professional development requirements as outlined in the Membership Agreement.
17.2 Failure to comply may result in suspension or termination of Membership.

18. Reporting and Grievance Handling

18.1 Agents are responsible for addressing client complaints or grievances promptly.
18.2 Escalations should be directed to The JLT Group in cases where a resolution cannot be achieved.
18.2.1 These escalations should be forwarded to

19. Disciplinary Framework

19.1 Violations of this Code of Conduct will be addressed through a structured disciplinary process, including but not limited to:
19.1.1 Formal written warnings.
19.1.2 Temporary suspension of Membership privileges.
19.1.3 Termination of Membership for severe or repeated violations.
19.2 Investigations will be conducted fairly, and Agents will be given the opportunity to provide their account of events.

20. Compliance Audits

20.1 The JLT Group reserves the right to conduct compliance audits to verify adherence to the Code of Conduct and Membership Agreement.
20.2 Agents must cooperate fully during such audits and address any identified issues promptly.

21. Health and Safety

21.1 Agents must promote safe practices in their professional environment and adhere to health and safety standards applicable to their activities.

22. Prohibition of Unlawful Practices

22.1 The JLT Group maintains a strict zero-tolerance policy for any unlawful or unethical practices. Agents must conduct their activities in full compliance with all applicable laws and regulations, including, but not limited to, consumer protection laws, anti-fraud laws, and data protection laws.
22.2 Agents are explicitly prohibited from engaging in any of the following practices:
22.2.1 Fraudulent or deceptive activities, including providing false information to clients, suppliers, or The JLT Group.
22.2.2 Bribery or corruption, including offering, giving, receiving, or soliciting any form of payment or benefit to influence decisions unlawfully.
22.2.3 Anti-competitive behaviour, such as colluding with competitors to fix prices, limit competition, or manipulate the market.
22.2.4 Misrepresentation of services, including making false claims about travel packages, insurance coverage, or supplier terms.
22.2.5 Unauthorised use of client funds or The JLT Group's resources for personal gain or purposes outside the scope of authorised activities.
22.3 Agents must ensure compliance with all applicable regulatory frameworks, including UK consumer protection laws, GDPR, and ATOL regulations, as well as any international laws applicable to their operations.
22.4 Agents are required to report any suspected or actual unlawful practices within The JLT Group network to the Company's management immediately. This includes activities by other agents, suppliers, or third parties.
22.5 Whistleblower protections are in place to encourage reporting without fear of retaliation.
22.6 Violations of this clause will result in severe disciplinary measures, including but not limited to:
22.6.1 Suspension of Membership privileges.
22.6.2 Immediate termination of Membership.
22.6.3 Legal action to recover damages or report unlawful activity to the appropriate authorities.
22.7 Agents acknowledge that they bear full responsibility for their actions and any legal or financial consequences arising from unlawful practices.
22.7.1 The JLT Group reserves the right to cooperate fully with law enforcement or regulatory authorities in the investigation of unlawful practices.

23. Acknowledgment and Compliance

23.1 By maintaining Membership with The JLT Group, Agents acknowledge and agree to comply with the terms outlined in this Code of Conduct.
23.2 Agents acknowledge that they have read, understood, and agree to be bound by this Code of Conduct.
23.3 Agents acknowledge that this Code of Conduct forms an integral part of the Membership Agreement and that violations may result in disciplinary action, including suspension or termination of Membership.

END OF CODE OF CONDUCT