MODERN SLAVERY AND HUMAN TRAFFICKING POLICY

Circulayo has a zero‑tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business relationships and to implementing effective systems and controls to ensure that slavery and human trafficking are not taking place anywhere in our own business or in any of our supply chains.

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Modern slavery describes situations where an individual is forced into labour, controlled by an employer, treated as a commodity or physically constrained. Human trafficking involves illegally transporting people for exploitation. Organisations must condemn these practices and ensure they do not occur in any part of their business or supply chains.

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Our commitments include:

• Condemning modern slavery and human trafficking and dedicating ourselves to ensuring these practices do not occur in our operations or supply chains.

• Assessing and mitigating risks of slavery and trafficking by identifying high‑risk areas within our business and supply chains and implementing controls to address them.

• Applying a zero‑tolerance attitude towards suppliers who fail to meet our standards and conducting supplier audits to ensure compliance.

• Providing training to employees on recognising signs of modern slavery and reporting concerns.

• Referencing our recruitment, whistleblowing and code of conduct policies to ensure eligibility checks and encourage reporting of concerns.

• Ensuring this policy is approved by the board and signed at senior level; it will be published and reviewed annually.