MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT

Introduction

This statement sets out the Circular1 Health Limited actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 15^th April 2022 – 15^th April 2023.

As part of the healthcare sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and, especially given the nature of our business, we continue to take our responsibility very seriously during the coronavirus pandemic.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Circular1 Health Limited.  The team consists of business experts, scientists and engineers working with partners and collaborators to deliver outstanding products and services. At our core Circular 1 is focused on sustainability from both a business continuity and ecological point of view.

Circular1 provides Covid-19 testing and screening service, fixed and mobile laboratories, biosecurity, anti-virus entry systems, track and trace solution, and Wellbeing App to support employers and assist with business continuity.

Our supply chains include purchasing materials, sub-contracting, consultants, environmental and other associated trades and services connected with our industry. We have thorough due diligence processes for managing our relationships with our subcontractors and suppliers.

The obligations imposed by the Modern Slavery Act are clearly articulated in our agreements with sub-contractors and suppliers, they are required to provide a copy of their own or agree to follow our Modern Slavery statement prior to supporting our company.

Countries of operation and supply:

We currently operate in the UK however, in the event we expand to provide our service internationally, our commitment and approach to preventing slavery and human trafficking will be no less robust regardless of where we operate in the future.  We will undertake appropriate due diligence and assessment to assess whether or not particular activities or countries are high risk in relation to slavery or human trafficking.

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

• Circular1 Health uses a number of organisations to purchase supplies for its daily activities, therefore there is a risk of slavery or human trafficking as Circular1 Health has no control of its suppliers logistics. All approved suppliers are requested to provide a ‘modern slavery act’ statement before being used by Circular1 Health.

Responsibilities

Responsibility for our anti-slavery initiatives is as follows:

• Policies:

Our Human Resources Team is responsible for ensuring company policies are available via the internal HR Platform and any other methods of communication channels live at the time.

Policies are reviewed annually and approved by the Board of Directors.

• Risk Assessments:

The Company recognises that Modern Slavery (servitude, forced labour and human trafficking) is a global and ever-increasing issue. The following policy sets out the approach taken by the Company to understand and eliminate all potential Modern Slavery risks related to its business operations and activities.

The Company aims to have the highest ethical and professional standards and aims to always comply with all local laws and regulations applicable to the business. The Company is absolutely committed to preventing Modern Slavery activities within the business and within its supply chains. The Company plans to emphasise this commitment by ensuring all employees have received suitable and sufficient information, instruction and training relating to Modern Slavery. The Company also expects the same high standards which we set for ourselves from those parties with whom we engage, such as our suppliers and customers.

• Investigations

The Company will ensure that any suspicion of Modern Slavery is reported to the proper authorities and investigated internally. Employees are openly encouraged to report any concerns or suspicions to Senior Management. As with any issue or suspicion, these will be reported and investigated, with remedial action taken as necessary.

Due to the nature of our business and our approach to governance, we assess that there is very low risk of Modern Slavery in our business. The Company will aim to periodically review the effectiveness of this policy and update it accordingly. The future aims of the Company are to include information relating to Modern Slavery within our employee induction program to ensure any new employees are aware of our policy and commitment to high ethical standards.

This policy has been approved by the Managing Director and will be reviewed, and where required, revised on a regular basis.

This policy has been made pursuant to the Modern Slavery Act 2015.

• Training:

All policies are visible within the HR Platform and each policy is introduced to an employee within their Company Induction of which attendance is mandatory and audited on an annual basis.

Every policy is tracked within the HR Platform with a ‘read receipt’ and annual audits are conducted by the HR Team who subsequently encourage the reading and understanding of such policies directly with employees and their Line Managers.

Should training be available via an appointed eLearning provider then it is made available to employees and workers via the platform which is live at the time.

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our or our supply chain partners operations:

• Whistleblowing policy

We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our grievance system via our HR Platform or alternatively discuss with HR by sending an email to HR@circular1.com

• Supplier/Procurement code of conduct

We are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.

At Circular 1 Health to obtain services and supplies, which are satisfactory for the purpose intended. Manufacturers and suppliers of services are expected to be accredited to an appropriate ISO standard, UKAS and other relevant accreditation status to provide supplies and services to the standard required by the Management System. On yearly basis, Circular 1 Health ‘approved suppliers’ are asked to provide a statement of actions taken to address and reduce the risk of slavery and human trafficking. This is then reviewed on yearly basis by the Laboratory Quality Manager to ensure Circular 1 Health is taking all the necessary precautions to apply a robust anti-slavery and human trafficking policy.

• Recruitment/Agency workers policy

We use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. Should Circular1 be made aware or have any suspicions of unethical working procedures then this would be addressed by either our Executive Team or a member of the Human Resources Team. To conclude, discussions would be recorded in writing and saved alongside the existing supplier service level agreement.

• Any other policies relevant to our business or sector

All policies can be viewed and downloaded in PDF format via the HR Platform.

 

Standard Operating Procedures are visible and downloadable via the Quality Management System.

Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly review existing suppliers. Our due diligence and reviews include:

• Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking.
• Evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment];
• Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
• Conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified.
• Creating an annual risk profile for each supplier.
• Taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans;
• Participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
• When onboarding a new supplier we request the completion of a Supplier Check Form (SF-009.1) which ensures suppliers information on Quality, Modern Slavery Act, Insurance, Environmental Management, Heath & Safety and Security are all requested and reviewed before approval.   and
• Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

We continuously review our key performance indicators (KPIs). As a result, we are:

• Continually training new joiners on our commitment of reporting Modern Slavery and embed a culture of an open-door policy to encourage any communication around non-compliance
• A system for supply chain verification (TM-AD-004) is in place since 28^th September 2020, whereby we evaluate potential suppliers before they enter the supply chain; and
• reviewing existing supply chains expected to be completed on yearly basis for all approved suppliers. by, whereby we evaluate all existing suppliers on service, price and compliance.

Training

We require all staff within our organisation to complete training on modern slavery provided. This is embedded into our mandatory 90-minute Company induction. This training is delivered to new joiners within their first few weeks of onboarding with the Company. Existing workers are invited to the weekly training sessions until they attend.

We commit to exploring the delivery of awareness training via an eLearning platform. Our existing eLearning offering has the ability to offer a course test, setting pass marks and act as evidence of our compliance.

Should we introduce the eLearning training, this would be reviewed annually to ensure it remains compliant and up to date. Refresher courses are mandatory every two years. We require staff who are running a department or function to receive refresher training on an annual basis.

Our modern slavery training covers:

• Definitions of modern slavery
• Educating attendees on identifying signs of modern-day slavery and raise their awareness
• Give attendees the tools and confidence to speak up on modern day slavery
• How to report suspicious activities, including what initial steps should be taken if slavery or human trafficking is suspected and how to escalate matters via the relevant channels
• Awareness of where Modern Slavery Posters are visible across our locations. These posters contain contact telephone numbers and support channels to report activity.

Awareness-raising programme

As well as training staff, we have raised awareness of modern slavery issues by having posters in our locations and these posters available within our HR Platform. The posters inform staff of the contact details of the modern slavery helpline.

Board approval

This statement was approved on 13^th April 2022 by our board of directors, who review and update it annually.

Director’s/ name:

Stuart MacLennan

Date:

13.04.2022