The JLT Group Code of Conduct Policy

This Code of Conduct outlines the standards and expectations for all Members (Agents) of The JLT Group. The purpose of this policy is to ensure that all Agents represent The JLT Group with professionalism, integrity, and accountability while upholding the highest ethical standards. Adherence to this policy is a condition of Membership.

1.     Professionalism

1.1.  Agents must conduct themselves professionally in all communications and interactions with clients, suppliers, colleagues, consultants and The JLT Group staff.

1.2.  All Agents must adhere to the service standards outlined in the Membership Agreement to ensure a consistent and positive experience for clients and partners.

2.     Compliance with Laws and Regulations

2.1.  Agents must comply with all applicable laws, regulations, and industry standards, including but not limited to:

2.1.1.     ATOL regulations for licensable transactions.

2.1.2.     UK GDPR and Data Protection Act 2018 for client data handling.

2.2.  Breaches of legal or regulatory requirements may result in immediate termination of Membership.

3.     Integrity and Ethical Conduct

3.1.  Agents must act honestly, transparently, and ethically in all business dealings and communications. 

3.1.1.     Upholding integrity is a fundamental requirement for representing The JLT Group.

3.2.  Agents must not engage in any fraudulent activities or misconduct. 

3.2.1.     Fraud is defined as any intentional deception, misrepresentation, or omission of material facts with the aim of personal gain or to cause loss to 

3.2.1.1.         The JLT Group, clients, suppliers, or any other parties. Examples include, but are not limited to:

3.2.1.1.1.             Misrepresentation of client bookings or supplier offerings.

3.2.1.1.2.             Submission of false documentation or information to The JLT Group, clients, or suppliers.

3.2.1.1.3.             Misappropriation of client funds or company resources.

3.2.1.1.4.             Unauthorised alteration of contracts, policies, or booking terms for personal benefit.

3.3.  Fraudulent activities are considered gross misconduct and will result in immediate termination of Membership. 

3.3.1.     Additionally, The JLT Group reserves the right to pursue legal action to recover losses and will report the fraud to relevant authorities.

3.4.  Agents must report any suspected fraudulent activities or unethical behaviour within The JLT Group network to the Company immediately. 

3.4.1.     Whistleblower protections are in place to ensure such reports can be made without fear of retaliation.

3.5.  Ethical conduct also extends to conflict resolution and managing disputes professionally. 

3.5.1.     Agents must avoid actions that could jeopardise client trust or the professional reputation of The JLT Group.

4.     Anti-Harassment and Non-Discrimination

4.1.  The JLT Group is committed to creating a respectful, inclusive environment.

4.2.  Agents must not engage in any form of harassment, discrimination, or inappropriate behaviour based on race, gender, age, disability, religion, sexual orientation, or any other protected characteristic.

5.     Protection of The JLT Group’s Reputation

5.1.  Agents are expected to uphold and enhance the reputation of The JLT Group in all professional interactions, whether with clients, suppliers, or colleagues.

5.2.  Actions that could bring The JLT Group into disrepute, either intentionally or unintentionally, will not be tolerated. Examples of such actions include:

5.2.1.     Making unprofessional or negative public statements about The JLT Group, its policies, suppliers, or other agents.

5.2.2.     Inappropriate behaviour during client or supplier interactions that reflects poorly on The JLT Group.

5.2.3.     Misuse of The JLT Group’s branding, logo, or promotional materials in a manner that does not align with the Company’s standards.

5.2.4.     Engaging in activities that conflict with the ethical principles or service standards upheld by The JLT Group.

5.3.  Agents are responsible for reporting incidents or situations that could damage the reputation of The JLT Group to management immediately. This includes flagging any inappropriate use of The JLT Group’s name, branding, or marketing materials by themselves or others.

5.4.  Any breach of this clause may result in disciplinary action, which could include a formal warning, suspension of Membership privileges, or termination of Membership.

5.5.  The JLT Group reserves the right to take legal action to protect its reputation in the event of serious violations, including seeking damages for reputational harm.
 

6.     Confidentiality

6.1.  The Agent acknowledges that during the course of their Membership, they will have access to The JLT Group’s proprietary information, including but not limited to:

6.1.1.     Business strategies, financial information, supplier agreements, and commission structures.

6.1.2.     Operational guidelines, training materials, and booking systems.

6.1.3.     Sensitive client information such as personal details, booking histories, and preferences.

6.2.  The Agent agrees to maintain strict confidentiality of all such information and must not disclose it to any third party without prior written consent from The JLT Group.

6.3.  Confidential information provided by The JLT Group must only be used for authorised purposes directly related to the Agent’s duties and obligations under the Agreement.

6.4.  Under no circumstances shall the Agent use confidential information for personal gain, competitive advantage, or any purpose that may harm The JLT Group.

6.5.  The Agent must ensure the secure handling and storage of all confidential information, employing appropriate measures to prevent unauthorised access, disclosure, or loss.

6.6.  Electronic records must be stored in password-protected devices, and physical documents containing sensitive information must be securely locked away when not in use.

6.7.  Upon termination of Membership, the Agent must immediately return or destroy, as directed by The JLT Group, any confidential information in their possession, including all copies or reproductions in any format.

6.8.  This confidentiality obligation survives the termination of the Agreement indefinitely. 

6.8.1.     The Agent remains bound by these terms and may not disclose or use The JLT Group’s confidential information for any purpose after the end of their Membership.

6.9.  The Agent must report any suspected or actual breaches of confidentiality to The JLT Group immediately. 

6.9.1.     This includes any unauthorised access to proprietary or client information, data breaches, or accidental disclosures.

6.10.               The JLT Group reserves the right to pursue legal remedies for any breach of confidentiality. 

6.10.1. This includes, but is not limited to, seeking injunctive relief, damages, or reporting violations to the relevant regulatory authorities.

7.     Client Relationships and Responsibilities

7.1.  Agents must prioritise professionalism, transparency, and fairness in all dealings with clients.

7.1.1.     Agents must actively listen to client needs, provide tailored solutions, and maintain clear and respectful communication throughout the booking process.

7.1.2.     Misleading or overpromising clients is strictly prohibited and may result in disciplinary action.

7.2.  Agents are required to provide clients with precise and truthful information regarding travel options, booking terms, and associated costs, ensuring that all details are fully disclosed before confirmation.

7.3.  Hidden fees or charges must not be applied without prior discussion and agreement with the client.

7.4.  Agents must ensure the protection of client data in compliance with data protection laws, including the UK GDPR. Personal information such as contact details and travel itineraries must be handled securely and only used for booking purposes.

7.5.  Sharing client details with third parties without explicit consent is prohibited.

7.6.  Clients who raise concerns or complaints must be treated respectfully, and all efforts must be made to address and resolve their issues promptly.

7.6.1.     If a satisfactory resolution cannot be achieved at the Agent level, complaints must be escalated to The JLT Group’s support team in accordance with established procedures.

7.7.  Agents must continue to provide support to clients after bookings have been confirmed, including addressing any questions, modifications, or issues arising during travel.

7.8.  Agents must inform clients promptly of any changes or cancellations to their bookings caused by suppliers, and assist them with alternative arrangements or refunds as necessary.

7.9.  Agents are responsible for ensuring that client bookings comply with the terms set by suppliers, The JLT Group’s policies, and applicable regulations (e.g., ATOL).

7.9.1.     Agents must familiarise themselves with supplier-specific terms and conditions to avoid misunderstandings or disputes.

7.10.               All client payments must be handled in strict accordance with PTS Trust guidelines and The JLT Group’s financial policies.

7.10.1. Mismanagement of funds, such as failing to pass payments to suppliers on time, will be treated as a serious breach of this Code.

7.11.               Agents are expected to prioritise the safety and welfare of clients by providing accurate travel advisories, visa requirements, and insurance options.

7.11.1. Clients must be informed of any risks associated with their travel plans and guided to make informed decisions.

7.12.               Agents are encouraged to build trust and foster long-term relationships with clients through consistent and exemplary service.

7.12.1. Repeat clients and referrals reflect positively on both the Agent and The JLT Group.

7.13.               Under no circumstances should an Agent pressure or coerce clients into making bookings.

7.14.               Misrepresentation of travel products, unauthorised alterations to bookings, or tampering with client preferences is strictly prohibited and will result in disciplinary action.

8.     Branding and Marketing 

8.1.  Agents must ensure that all branding, marketing materials, and communications align with The JLT Group’s official branding guidelines. This includes the proper use of logos, colour schemes, and approved language in advertisements, social media posts, and promotional content.

8.1.1.     Unauthorised modifications to the branding, such as altering logos or using non-approved taglines, are prohibited.

8.2.  Agents are required to represent The JLT Group professionally in all forms of media, whether online or offline. Any messaging must reflect the Company’s commitment to excellence, transparency, and ethical practices.

8.2.1.     Agents must refrain from making exaggerated or misleading claims in marketing campaigns that could harm the reputation of The JLT Group or lead to client dissatisfaction.

8.3.  When using social media to promote services associated with The JLT Group, Agents must maintain professionalism and avoid posting offensive, discriminatory, or controversial content that could negatively impact The JLT Group’s image.

8.3.1.     All social media posts must clearly distinguish the Agent’s personal views from those of The JLT Group, ensuring there is no confusion about the source of statements or opinions.

8.4.  Agents must not engage in unsolicited marketing practices such as spam emails, cold calling, or unauthorised messaging, as these practices may violate data protection and consumer rights laws.

8.5.  The JLT Group’s name, logo, trademarks, and proprietary materials must only be used for approved marketing and promotional purposes.

8.5.1.     Agents are strictly prohibited from using The JLT Group’s intellectual property in a manner that suggests unauthorised partnerships or endorsements.

8.6.  Any misuse or violation of branding and marketing guidelines may result in immediate disciplinary action, including the suspension of Membership privileges or termination of Membership.

8.7.  Agents are encouraged to develop creative marketing initiatives that align with The JLT Group’s ethical standards and enhance the Company’s image. 

8.7.1.     Collaborative opportunities for campaigns may be explored with prior approval from the Company.

8.8.  Agents are responsible for staying updated on any changes to The JLT Group’s branding guidelines, policies, or marketing requirements. Regular communication with the Company’s support team is recommended for clarifications or guidance.

9.     Financial Responsibility 

9.1.  Agents must manage client funds with the utmost care, ensuring compliance with The JLT Group’s financial policies and PTS Trust guidelines.

9.2.  All payments received from clients must be promptly and accurately processed in accordance with the agreed booking terms. Mismanagement, delays, or improper handling of client funds is strictly prohibited.

9.3.  Agents are required to provide clients with clear and detailed financial breakdowns of all transactions, including service fees, insurance costs, and other charges.

9.3.1.     Agents must not add or conceal fees without prior client knowledge and consent.

9.4.  Agents must comply with all policies and procedures outlined by designated merchant processors for card payments. This includes accurately reporting payment details and ensuring secure transactions.

9.4.1.     Any fees related to credit or debit card payments must be clearly communicated to clients upfront and should be handled responsibly by the Agent.

9.5.  Agents are responsible for ensuring that client accounts are accurate and transparent to minimise disputes or chargebacks.

9.5.1.     In the event of a dispute or chargeback, the Agent will bear full financial liability and any associated administrative fees as outlined by The JLT Group.

9.6.  To safeguard client interests, Agents must ensure all transactions are processed through secure payment systems approved by The JLT Group.

9.6.1.     In cases where client refunds are due, Agents must coordinate promptly to initiate and process refunds in line with The JLT Group’s policies.

9.7.  Agents will be held accountable for errors, omissions, or mismanagement related to client funds or financial transactions.

9.8.  The JLT Group reserves the right to recover any losses or damages caused by the Agent’s failure to manage funds responsibly.

9.9.  Agents must ensure compliance with all relevant legal, financial, and tax regulations in their country of operation, including timely payment of taxes and fees owed on commissions earned.

9.9.1.     Failure to comply with financial or tax obligations may result in disciplinary action and legal consequences.

9.10.               Under no circumstances shall Agents engage in fraudulent financial practices, such as:

9.10.1. Misrepresentation of fees or charges.

9.10.2. Misuse of client funds for personal purposes.

9.10.3. Altering payment records to conceal inaccuracies.

9.10.4. Any such misconduct will result in immediate termination of Membership and may lead to legal action.

10.  Data Protection 

10.1.               Agents must comply with all applicable data protection laws and regulations, including but not limited to the UK GDPR, the Data Protection Act 2018, and any other relevant international or local data protection laws.

10.2.               Agents must ensure that all personal data they process, including client and supplier information, is securely stored, accessed, and transmitted. Appropriate technical and organizational measures must be implemented to protect data from unauthorised access, accidental loss, destruction, or damage.

10.2.1. Examples of secure handling include:

10.2.1.1.      Using strong, unique passwords for electronic devices and systems.

10.2.1.2.      Encrypting sensitive files and communications where possible.

10.2.1.3.      Securing physical documents containing personal data in locked storage when not in use.

10.3.               Personal data must only be collected, processed, and retained for specific, legitimate purposes directly related to fulfilling The JLT Group’s services. Under no circumstances should data be used for unauthorised purposes, including personal gain or third-party benefit.

10.4.               Agents must retain personal data only for as long as it is necessary to fulfil the intended purpose or to meet legal and regulatory obligations. Once the data is no longer required, it must be securely deleted or destroyed.

10.5.               Any actual or suspected data breaches, including unauthorised access or data loss, must be reported to The JLT Group immediately. 

10.5.1. Agents must cooperate fully in breach investigations and assist in mitigating potential harm to affected individuals.

10.6.               Failure to report data breaches promptly or attempts to conceal breaches will result in severe disciplinary action and may include legal action. 

10.7.               Agents must ensure that clients are informed about how their data will be used, stored, and shared.

10.7.1. Where required by law, Agents must obtain explicit consent from clients for specific data processing activities, ensuring such consent is recorded and stored securely.

10.8.               Agents are required to undergo data protection and privacy training as part of their onboarding process and annual compliance updates. Failure to complete required training may result in suspension of Membership privileges.

10.9.               Agents must only share personal data with third-party processors (e.g., suppliers, partners) who demonstrate compliance with data protection laws. Agents must ensure that third parties uphold the same data protection standards expected by The JLT Group.

10.10.            The JLT Group reserves the right to conduct periodic data protection audits to ensure compliance with this policy. Agents must cooperate fully with these audits and implement any corrective actions recommended by The JLT Group.

10.11.            Agents are accountable for the personal data they handle and are expected to demonstrate compliance with data protection laws and this policy at all times.

10.11.1.                In instances of non-compliance, The JLT Group reserves the right to impose penalties, including Membership suspension or termination, and may report serious violations to the relevant data protection authorities.

11.  Digital Conduct

11.1.               Agents must maintain professionalism in all online interactions, including social media posts and participation in The JLT Group’s WhatsApp community.

11.2.               Use of The JLT Group’s communication platforms must align with the policies set forth by the Company and must not be used for personal or unauthorised purposes.

12.  Whistleblower Protections

12.1.               The JLT Group is committed to fostering an ethical, lawful, and transparent working environment. Agents are encouraged to report concerns about misconduct, unethical behaviour, or violations of laws, regulations, or company policies, including this Code of Conduct.

12.1.1. Whistleblowing ensures the integrity of The JLT Group's operations and protects the interests of clients, suppliers, and all stakeholders.

12.2.               Agents are expected to report any activities that may constitute:

12.2.1. Fraud, corruption, or financial misconduct.

12.2.2. Breaches of legal or regulatory requirements, including GDPR violations or consumer protection issues.

12.2.3. Harassment, discrimination, or other forms of inappropriate behaviour.

12.2.4. Conflicts of interest or unethical business practices.

12.2.5. Mismanagement of client funds or misuse of company resources.

12.3.               Agents can report concerns through the following formal and confidential channels:

12.3.1. Email:

12.3.2. Written reports sent to The JLT Group’s compliance officer at the company’s registered office.

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 victimization 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 authorized 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 – Support@thejltgroup.co.uk

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 authorized 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.

1. Introduction

This Agreement outlines the terms and conditions under which the Agent is granted membership within The JLT Group. By entering into this Agreement, the Agent agrees to comply with all policies, guidelines, and operational standards outlined by The JLT Group.

2. Membership Terms

2.1 Membership is granted on a non-exclusive, non-transferable basis.

2.2 Membership does not constitute an employment relationship, joint venture, or partnership. 

2.3 Membership is subject to periodic review by The JLT Group and may be revoked if the Agent fails to meet required standards.

3. Services Provided by JLT

3.1 The Agent is authorised to book holidays and travel services for their clients through The JLT Group’s preferred suppliers. 

3.2 All bookings must comply with the terms and conditions set out by the suppliers and The JLT Group. 

3.3 The Agent acknowledges that they act as an intermediary and that clients must be informed of the applicable booking terms. 

3.4 The Agent is required to adhere to JLT’s service delivery and communication standards to ensure a consistent client experience.

4. Agent Responsibilities

4.1 Act professionally, ethically, and in compliance with all applicable laws and regulations. 

4.2 Protect and promote the reputation of The JLT Group. 

4.3 Provide clients with accurate and transparent information. 

4.4 Ensure adherence to the Company's branding and marketing guidelines. 

4.5 Keep all proprietary and client information confidential. 

4.6 Notify the Company promptly of any circumstances affecting Membership obligations.

5. Fees, Payments, and Adding Team Members

5.1 Joining Fee: The Agent agrees to pay a one-time, non-refundable joining fee as specified in the Appendix.

5.2 Membership Fees: Membership fees are payable every 28 days as follows:

·       Business Class Membership: £87 every 28 days.

·       First Class Membership: £127 every 28 days.

5.3 Adding Team Members: At the sole discretion of The JLT Group, the Agent may add team members to their membership.

·       Duo and Trio Accounts:

o   A non-refundable fee of £150 per additional agent applies.

o   The Agent’s membership fee will increase by 47% for each added member.

o   The Agent retains full responsibility for the conduct, compliance, and actions of any additional agents added to their membership and accepts full liability for them.

5.4 Late Payments: Failure to make payments on time may result in an administrative fee of £25. This fee shall apply for each attempt made by The JLT Group to recover missed membership fees. Additionally, the administrative fee will be applied to any costs or fees incurred by The JLT Group due to actions or omissions by the Agent, including but not limited to processing delays, penalties, or other liabilities.

5.5 Refund Policy: All fees are non-refundable except under exceptional circumstances, at the sole discretion of The JLT Group.

5.6 Membership Fee Adjustments: Membership fees are subject to annual review and may be adjusted based on inflation or operational requirements.

5.7 Cancellation Policy: The business reserves the right to charge the final month of the membership fee upon receipt of cancellation.

5.8 Booking Fees and Insurance Requirements: In accordance with UK law, travel agents must add specified booking fees and applicable insurances to each booking transaction. Agents may incorporate these fees into the final client quotation so that they are absorbed within the total balance.

5.9 Credit and Debit Card Fees: Agents are responsible for covering all credit and debit card processing fees associated with incoming payments via the designated merchant processor. Agents may pass these costs onto the Client. 

5.10 Training and Compliance:

·       Agents must complete and fully understand all training provided by the JLT Academy.

·       Certification by JLT Academy management is required before an agent is authorised to make bookings.

·       Agents must adhere to the guidelines outlined in Schedule 3 to ensure compliance with financial and consumer protection regulations, including the PTS Trust principles.

5.11 Implementation of Training:

·       Agents are solely responsible for applying the training received in their day-to-day operations.

·       Any questions or clarifications regarding training content must be promptly addressed with the franchise support team.

5.12 Client Fund Handling:

·       Agents must ensure that all client funds are managed in strict accordance with the PTS Trust guidelines.

·       Compliance with established procedures and protocols is mandatory to safeguard client funds and maintain regulatory adherence.

5.13 Audit and Compliance Checks: The JLT Group reserves the right to conduct periodic audits and compliance checks to verify that agents adhere to prescribed procedures and guidelines. Failure to comply may result in disciplinary action, including suspension or termination of membership.

5.14 The non-refundable nature of fees shall not apply in circumstances where the cancellation or termination is the result of the Company failing to deliver on agreed services, as mandated by the Consumer Rights Act 2015.

6. WhatsApp Community Access

6.1 As part of their Membership, the Agent is granted access to The JLT Group’s WhatsApp community. 

6.2 Access to this community does not form part of this Agreement. 

6.3 The WhatsApp community is intended as a platform for Agents to connect, share best practices, and collaborate informally. 

6.4 The Company reserves the right to remove any Agent from the WhatsApp community at its sole discretion. 

6.5 The WhatsApp community is not a dedicated support function offered by The JLT Group, and any formal support must be accessed through the appropriate channels outlined in this Agreement.

7. Confidentiality

7.1 The Agent acknowledges that they will have access to proprietary information and agrees not to disclose or share such information without prior consent from the Company. 

7.2 This confidentiality obligation survives the termination of this Agreement indefinitely.

8. Data Protection and GDPR Compliance

8.1 The Agent agrees to comply with the UK GDPR, Data Protection Act 2018, and any applicable data protection laws. 

8.2 The Agent will ensure the secure storage of all personal data they process. 

8.3 Data breaches must be reported to the Company immediately.

8.4 The Company will process the Agent's data in accordance with its Privacy Policy.

8.5 The Agent must obtain explicit consent from clients before collecting, storing, or processing their personal data, in compliance with UK GDPR regulations. Such consent must be documented and retained for audit purposes.

8.6 The Agent shall provide clients with a clear Privacy Notice detailing how their personal data is handled, including purposes of processing, retention periods, and rights under data protection laws.

9. Compliance with ATOL Regulations

Definitions

The definitions used in this agreement have the same meaning as those used in the ATOL Regulations 2012 (as amended). Additionally, ‘Licensable Transaction’ means an offer made by a consumer (or their agent) to purchase flight accommodation for one or more persons on a flight which is accepted by an air travel organiser and constitutes an activity in respect of which that air travel organiser is required to hold an ATOL.

Extent of obligations

The obligations of all parties to this agreement extend only to the parties’ conduct in respect of licensable transactions

Priority of Agency terms published by CAA

Pursuant to AST 2.2 and Agency Term 1 no agency term negotiated between the principal ATOL holder and the agent may contradict or purport to contradict the CAA’s mandated terms and any that do so will be void.

Agency Term 1

By making available flight accommodation to consumers in the capacity of an agent, in accordance with ATOL Regulations 9, 10 and 12 the agent is deemed to have agreed to the terms of the written agency agreement between the principal ATOL holder and its agent. The terms of the agency agreement include terms mandated by the CAA to be agreed between principal ATOL holders and agents for principal ATOL holders making available flight accommodation as agents of that principal ATOL holder. Principal ATOL holders and agents cannot agree, whether in writing, by conduct or otherwise, any terms which contradict, or purport to contradict the terms mandated by the CAA. The agent must keep a copy of this agency agreement for the period it is in force and for 12 months after it expires or is terminated.

Agency Term 2

2.1 Agents must comply with ATOL Standard Term 1 as if they applied directly to the agent (as applicable) and any requirements to set out the principal ATOL holder’s name and number should be read as requirements to set out the principal’s name and ATOL number. For the avoidance of doubt, agents are not permitted to use the ATOL logo without the permission of the CAA\ Agency Term. 

2.2 The agent must at all times identify the selling, protecting principal ATOL holder on all publicity material (including websites and brochures) that identify a flight or flight inclusive package which the agent is holding out it can make available to consumers. Agency Term. 

2.3 Where the agent produces a receipt for money paid by a consumer the agent must identify which part of that money is protected by the principal ATOL holder’s ATOL and which, if any, is not.

Agency Term 3

The agent will, if requested by the CAA, report to the principal ATOL holder the unique reference number of each ATOL Certificate supplied by it, along with the corresponding ATOL holder’s reference number, where it acts as agent for the principal ATOL holder and where the transaction with the consumer was a Flight-Only or a package. If requested to do so by the CAA at any time, and including after the failure of the principal ATOL holder, the agent will provide this information to the CAA.

Agency Term 4

The agent will provide any information requested by the principal ATOL holder necessary to enable the principal ATOL holder to comply with the ATOL Standard Terms or any term of its ATOL.

Agency Term 5

Any payment received by the agent from consumers, for services owed by the principal ATOL holder to the consumer, is received and held by the agent on behalf of and for the benefit of the Trustees of the Air Travel Trust but subject to the agent’s right and obligation to make payment to the principal ATOL holder for so long as the principal ATOL holder does not fail. If the principal ATOL holder fails, the agent confirms it will continue to hold consumer payments on behalf of the Trustees of the Air Travel Trust and without any right or obligation to pay the same to the principal ATOL holder.

Agency Term 6

6.1 Where an agent makes available flight accommodation as the agent of a principal ATOL holder, the agent must ensure an ATOL Certificate is supplied to the consumer immediately and in accordance with ATOL Regulation 17, regardless of whether the ATOL Certificate is produced by the principal ATOL holder or produced by the agent on behalf of the principal ATOL holder. However, if an agent organises a package which includes that flight accommodation, the agent must immediately supply a package ATOL Certificate to the consumer in the agent’s own name. Agency Term. 

6.2 Where an agent makes available a package as agent of a principal ATOL holder, the agent must additionally obtain a Confirmation (see AST 1.11) from the ATOL holder and, once obtained, pass it immediately to the consumer by the method set out below. Where an agent receives any revised Confirmation from the principal ATOL holder, it will immediately pass it to the consumer by the method set out below 

Note: The method for the supply of a Confirmation means: 

a) in the case of a consumer who is present at the time the agent receives the Confirmation, immediately handing it to that consumer or sending it to that consumer by electronic communication; 

b) in the case of a consumer who is not present at the time the agent receives the Confirmation, immediately sending it to that consumer by electronic communication or by post.

Agency Term 8

Immediately upon the failure of the principal ATOL holder, the agent will provide the CAA with information on: a) money paid to it by consumers, in respect of services to be provided for future travel by the principal ATOL holder to consumers; and b) the ATOL Certificate unique reference numbers issued by that agent which apply to that failed ATOL holder, in a form acceptable to the CAA.

Agency Term 9

The rights of the CAA and the Trustees of the Air Travel Trust to enforce any obligations under this agreement on either party are not excluded. For the avoidance of doubt, they may be enforced by the CAA and the Trustees of the Air Travel Trust. 

Agency Term 10 An agent is not permitted to appoint a sub-agent to perform its obligations as an agent of the principal ATOL holder on the agent’s behalf. 

Note: In these circumstances, as well as the agent being liable to the consumer as a principal, both the ‘agent’ and ‘sub-agent’ would be acting in breach of the ATOL Regulations 2012.

Agency Term 11

If a new or revised Schedule of Agency Terms is published by the CAA in its Official Record Series 3 those new or revised terms will immediately take effect and must be included in the terms of the agency agreement between the principal ATOL holder and the agent within 3 calendar months of the publication date. 

Note: a written agency agreement will be deemed to be compliant with ATOL Regulation 22(2)(c) provided that it contains all relevant parts of the schedule of agency terms published by the CAA in its Official Record Series 3 within 3 calendar months of the publication date.

Agency Term 12

If the principal ATOL holder fails to comply with its obligations to a consumer and by reason thereof the agent incurs a liability or obligation to the consumer, the agent shall be indemnified by the principal ATOL holder against all consequences following from such a failure. 

Agency Term 13

If requested by the CAA the agent will provide any information regarding the principal ATOL holder referred to in AST 4 which it holds to the CAA on demand.

9.1 The Agent is required to comply with all relevant ATOL (Air Travel Organiser's Licence) regulations when engaging in any bookings or travel-related activities as part of their membership with The JLT Group. 

9.2 The Agent must ensure that any bookings requiring ATOL protection are processed in accordance with the applicable regulations and that the appropriate documentation is issued to clients. 

9.3 Failure to comply with ATOL regulations may result in termination of Membership and/or additional liabilities. 

9.4 The JLT Group will provide guidance on ATOL compliance; however, the Agent retains full responsibility for adhering to these legal requirements.

9.5 The Agent shall undergo periodic training sessions provided by The JLT Group to stay updated on changes to ATOL regulations and ensure ongoing compliance.

9.6 The Agent agrees to submit a yearly compliance report to The JLT Group, confirming adherence to all ATOL-related obligations.

10. Non-Compete and Non-Solicitation

10.1 The Agent agrees not to engage with, represent, or solicit business from direct competitors of The JLT Group during Membership and for 3 months following termination.
10.2 The Agent will not solicit agents, clients, employees, or contractors of The JLT Group during Membership or within 3 months after termination.
10.3 For the avoidance of doubt, the Agent may not engage with, represent, or act on behalf of any other travel agency, host agency, or similar organisation whilst an active Member of The JLT Group, including during any notice period served to end Membership.

11. Independent Contractor and Self-Employment Status

11.1 The Agent acknowledges that they are self-employed and are not an employee, agent, or partner of The JLT Group. 

11.2 The Agent has complete freedom to operate their own business as they wish, provided they comply with The JLT Group’s policies, standards, and legal responsibilities. 

11.3 The Agent shall bear sole responsibility for their tax, National Insurance contributions, and other financial obligations. 

11.4 Nothing in this Agreement shall be construed as creating a relationship of employer and employee.

11.5 The Agent acknowledges they have no entitlement to employment-related benefits, including but not limited to holiday pay, sick pay, or pensions, thereby affirming their independent contractor status.

12. Insurance Requirements

12.1 The JLT Group provides insurance coverage for the Agent under the Group's insurance policy. This coverage includes public liability and professional indemnity, but it explicitly excludes coverage for any errors or omissions by the Agent ("Agent Error").

12.2 The Agent can source their own professional indemnity insurance throughout their Membership term to cover all potential liabilities arising from Agent Error. This includes, but is not limited to, errors in booking, administrative oversights, or other professional mistakes impacting clients or third parties. This is optional. 

12.3 The Agent acknowledges that all liabilities resulting from their errors or omissions remain solely their responsibility and are not covered by The JLT Group's insurance policy.

13. Training Requirements

13.1 The Agent must complete mandatory training upon joining and comply with all ongoing and annual training updates required by The JLT Group.

13.2 Following the initial Training Academy, the Agent will enter an 8-week probationary period, during which time they will receive additional support and coaching to assist with their first bookings. This extended training phase is designed to ensure the Agent reaches an appropriate level of understanding and capability before being fully signed off and moved into the main agent group.

13.3 Non-completion of training or failure to demonstrate the required level of competency during the probationary period may result in suspension of Membership privileges.

14. Chargebacks and Liability Clause

14.1 The Agent is solely responsible for all financial chargebacks, including bank chargebacks, related to bookings made for their clients. 

14.2 The Company may charge an administrative fee of £[XX] to the Agent for processing chargebacks or disputes. 

14.3 The Agent must reimburse the Company for any losses or penalties incurred due to chargebacks or disputes arising from their bookings.

15. Termination of Membership

15.1 Agents without any active bookings may terminate their Membership by providing 30 days’ written notice. 

15.2 Agents with active bookings are required to provide 90 days’ written notice prior to terminating their Membership, or alternatively, settle the account in full. 

15.3 Upon termination, the Agent must cease using all Company resources, systems, and branding immediately. 

15.4 The JLT Group reserves the right to revoke Membership for violations such as misconduct, non-payment, or breach of contract without prior notice.

16. Services and Support Availability

16.1 Services and support offered by The JLT Group are available during normal business hours, Monday to Friday, 9:00 AM to 5:00 PM, excluding bank holidays. 

16.2 All service and support requests must be sent via email to: support@thejltgroup.co.uk. 

16.3 Membership-related queries must be directed to: memberships@thejltgroup.co.uk

16.4 Commission & Refund related queries must be directed to: Accounts@thejltgroup.co.uk

16.5 The Agent acknowledges that requests received outside of normal business hours will be addressed on the next working day.

17. Booking Services Availability

17.1 Booking services are available to the Agent 24/7 through The JLT Group’s preferred suppliers. 

17.2 While booking services remain accessible at all times, The JLT Group’s core team will respond to and process service-related actions only during normal business hours, Monday to Friday, 9:00 AM to 5:00 PM, excluding bank holidays. 

17.3 Agents are encouraged to utilise the resources provided by preferred suppliers outside of core business hours for immediate needs.

18. Dispute Resolution and Governing Law

18.1 The Parties shall attempt to resolve disputes amicably through mediation. 

18.2 If mediation fails, disputes will be governed by and construed in accordance with the laws of England and Wales. 

18.3 Any disputes shall be subject to the exclusive jurisdiction of the courts located in London, England.

18.4 In the event of a dispute, the Parties agree to engage an independent mediation service, such as Wonderland People or UK Mediation, to facilitate an impartial resolution. The costs associated with the mediation shall be shared equally by the Parties unless otherwise agreed.

18.5 Costs associated with mediation shall be shared equally by the Parties unless otherwise agreed.

19. Indemnity

19.1 The Agent agrees to indemnify and hold harmless The JLT Group and its affiliates, directors, officers, employees, and agents from any claims, damages, losses, liabilities, and expenses (including reasonable legal fees) arising from:

·      The Agent’s actions or omissions in connection with this Agreement.

·      Breach of the terms and conditions set forth in this Agreement. 

19.2 This indemnification obligation shall survive the termination of this Agreement.

20. Code of Conduct

20.1 The Agent must uphold the highest standards of professionalism in all business activities. 

20.2 The Agent must avoid conflicts of interest and disclose any potential conflicts to The JLT Group. 

20.3 The Agent must not engage in harassment, discrimination, or any form of misconduct. 

20.4 The Agent agrees to adhere to the values and ethical standards outlined by The JLT Group.

20.5 The Agent agrees to ensure all services offered are accessible to clients with disabilities, as required under the Equality Act 2010. Reasonable adjustments must be made to accommodate clients’ needs.

21. Severability

21.1 If any provision of this Agreement is deemed invalid or unenforceable by a court of competent jurisdiction, such provision shall be severed, and the remaining provisions of this Agreement shall remain in full force and effect.

22. Force Majeure

22.1 Neither party shall be held liable for delays or failure in performance caused by events beyond their reasonable control, including but not limited to acts of God, natural disasters, war, governmental actions, or labour disputes. 

22.2 The affected party shall notify the other party as soon as possible and shall make reasonable efforts to resume performance under this Agreement.

23. Changes to Agreement

23.1 The JLT Group reserves the right to update or amend the terms of this Agreement with prior written notice to the Agent. 

23.2 Any changes shall take effect upon the Agent’s continued use of The JLT Group’s services or membership.

24. Commission Structure

24.1 The Agent shall receive a commission of 80% of the remaining revenue after all charges, fees, or deductions have been applied. 

24.2 The JLT Group will retain 20% of the remaining revenue following the deduction of all applicable charges and fees. 

25.3 Commission payments will be processed in accordance with The JLT Group’s payment policies and timelines. 

24.4 The JLT Group reserves the right to amend the commission structure at any time, provided that legally required notice is given to Agents prior to any changes taking effect. 

24.5 The Agent acknowledges that any disputes related to commission calculations must be raised within 30 days of receipt of payment, after which the calculation will be deemed final.

25. Entire Agreement

25.1 This Agreement represents the entire understanding between the Parties and supersedes all prior agreements, negotiations, and understandings, whether written or oral, related to the subject matter hereof. 

25.2 Any modifications to this Agreement must be made in writing and signed by both Parties.

26. Electronic Communications

26.1 Electronic signatures shall be deemed legally valid and binding in accordance with the Electronic Communications Act 2000.

26.2 All notifications and agreements communicated electronically must include a confirmation receipt from the receiving party to ensure acknowledgment.

Appendix A: Membership Fees and Charges

1.     Joining Fee: £297.00 (non-refundable).

2.     Membership Fees (payable every 28 days):

o   Business Class Membership: £87.

o   First Class Membership: £127.

3.     Fees for Adding Team Members:

o   Additional agent fee: £150 per agent (non-refundable).

o   Membership fee increase: 47% for each added team member.

o   The Agent shall bear sole responsibility for all costs and expenses associated with any additional agents added under their Membership.

4.     Late Payment Fee: £25. This fee is applied for each recovery attempt made for missed membership fees. It is also applied to cover any costs or fees incurred by The JLT Group due to the Agent's actions or omissions.

5.     Cancellation Fee: Equivalent to the final membership fee for the last month upon notice of cancellation.

Appendix B: Insurance Requirements

1.     The JLT Group provides insurance coverage under its Group policy. However, this coverage excludes Agent Error.

2.     Agents are required to maintain their own professional indemnity insurance throughout their Membership term to cover liabilities arising from Agent Error.

3.     Proof of insurance must be submitted upon request.

4.     Failure to comply with this requirement may result in suspension or termination of Membership.

Appendix C: Training and Compliance

1.     Completion of training provided by The JLT Academy is mandatory before making bookings*.

2.     Agents must adhere to compliance guidelines outlined in Schedule 3 and PTS Trust principles.

3.     Agents must undergo periodic training updates to ensure ongoing compliance.

Appendix D: ATOL Compliance

1.     Agents must process ATOL-protected bookings in strict accordance with ATOL regulations.

2.     ATOL Certificates must be issued to clients immediately as required by applicable laws.

3.     Agents are required to attend yearly training sessions to stay updated on ATOL compliance practices.

Appendix E: Dispute Resolution

1.     In the event of disputes, the Parties shall engage an independent mediation service, Wonderland People, to facilitate an impartial resolution.

2.     A fixed mediation cost of £1,500.00 has been agreed upon, which will be shared equally between the Parties unless otherwise agreed.

3.     Any additional costs arising from the mediation process, beyond the agreed amount, shall be borne by the respective Parties unless otherwise stipulated.

Appendix F: Commission Structure

1.     Agents are entitled to a commission of 80% of the remaining revenue after all applicable charges and fees.

2.     The JLT Group retains 20% of the remaining revenue.

3.     Commission disputes must be raised within 30 days of payment receipt; otherwise, calculations will be deemed final.

Appendix G: Key Financial Obligations

1.     Booking Fees: Agents must incorporate required booking fees into client quotations to ensure compliance.

2.     Credit and Debit Card Fees: Agents are solely responsible for all card processing fees.

*Pre-Sign-Off Booking Procedures

1.     Bookings Under Management of Authorised Agent:

o   The Agent grants the Authorised Agent the authority to make bookings on their behalf during the pre-sign-off period.

2.     Utilisation of Existing Quotes:

o   During the training period and before sign-off, the Agent may utilise and process any client quotes they have already prepared.

3.     Commission Structure for Pre-Sign-Off Bookings:

o   A distinct commission structure applies to bookings made during this period:

§  20% of the revenue is retained by The JLT Group.

§  The remaining 80% is equally split between the Agent and the Authorised Agent (40/40).

4.     Branding and Client Interaction:

o   The Agent is permitted to provide their clients with branded quotes and booking confirmations under their name and business branding.

5.     Booking Processing and Responsibility:

o   All bookings during this period will be processed and managed by the Authorised Agent, who will issue the necessary confirmations to the Agent.

o   The Agent acknowledges they bear full responsibility for their clients and any confirmed bookings made during this period.

6.     Restrictions on Booking Prior to Sign-Off:

o   No Agent is authorised to book any travel or activities prior to being officially signed off without the supervision of an authorised agent. Failure to comply with this requirement may result in the revocation of access or termination of Membership.