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Modern Slavery Policy

Policy Statement

Circle commits to developing and adopting a proactive approach to prevent, respond to and remediate the risks of modern slavery, forced and debt-bonded labour, human trafficking and hidden exploitation within its workplaces.

Modern slavery

A broad term used to encompass offences that involve one person depriving another person of their liberty, in order to exploit them for personal or commercial gain.

Forced labour

Is all work or service that is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.

Debt-bonded labour

Is where a person’s labour is demanded as a means of repayment for a loan or service.

Human trafficking

The recruitment and transportation of persons by threat, force, coercion or other abuse of power or vulnerability to achieve the consent of a person having control over another person for the purpose of exploitation.

Hidden labour exploitation

This is action up to and including modern slavery which involves the exploitation of workers and job applicants by internal or external individuals without the sanction or explicit knowledge of the employer or labour provider.


This policy applies throughout Circle IT Solutions Limited Ltd, at all office locations and to all members of staff with responsibility for recruiting and managing workers.


Jennifer Griffiths (Head of HR) has overall responsibility for the implementation of this policy.

Policy Commitments and Monitoring

Circle IT Solutions Limited shall:

  1. We have already registered on stronger2gether and have downloaded resources, presentations and induction materials as well as completed the good practice checklist.
  2. Add an agenda item to its quarterly supply chain and procurement meetings to include any policy updates or items associated with modern slavery risks.
  3. Commit to becoming a Stronger Together Business Partner by the end of 2022 and use the reporting tool to demonstrate progress.
  4. Designate appropriate managers - to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
  5. Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. The Company will not use any third party individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
  6. Ensure that all staff responsible for directly recruiting workers are aware of issues around third party labour exploitation and signs to look for and have conducted our Tackling Modern Slavery for Recruiters Training
  7. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
  8. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the police.
  9. Provide information on tackling “Hidden Labour Exploitation” to our workforce through a variety of formats including displaying posters in our offices, worker leaflets and through induction training
  10. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
  11. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities.
  12. Require other organisations under our control and operating within the labour supply chain to adopt policies and procedures consistent with the above, this will be a part of our supplier onboarding checks and noted as an agenda item for all quarterly supply chain meets.

Roger Harry

CEO, Circle IT Solutions Ltd, Brook House, Lime Tree Court, Mulberry Drive, Cardiff Gate Business Park, Cardiff, CF23 8AB

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