Modern Slavery Policy

This policy applies to all Stakeholders including all persons working for or on behalf of the Thirty-One Circles in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives fand business partners. This policy does not form part of any employee’s contract of employment and the Thirty-One Circles may amend it at any time.

 ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

Modern slavery is a crime and a violation of fundamental human rights taking various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Any reference in this policy to ‘modern slavery’ should be understood as a reference to modern slavery, human trafficking or any other activity that is rendered unlawful by the Modern Slavery Act 2015. Thirty-One Circles is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its business or supply chains. Thirty-One Circles is also committed to ensuring there is transparency in its business, consistent with our disclosure obligations under the Modern Slavery Act 2015. Thirty-One Circles expects the same high standards from all of its contractors, suppliers and other business partners. It will endeavour to ensure that provisions are included in agreements with all contractors, suppliers and other business partners requiring them to comply with the principles set out in this policy.

COMPLIANCE WITH THE POLICY

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for Thirty-One Circles or under its control. All Stakeholders are required to avoid any activity that might lead to a breach of this policy and must notify their manager or relevant contact in Thirty-One Circles as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future. Stakeholders are expected and encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the Thirty-One Circles business or supply chains of any supplier tier at the earliest possible stage (including if they are unsure about whether a particular act, the treatment of workers more generally, or their working conditions constitutes any of the various forms of modern slavery). Thirty-One Circles encourages openness and will support anyone who raises genuine concerns in good faith under this policy and are committed to ensuring no one suffers any detrimental treatment (including dismissal, disciplinary action, threats or other unfavourable treatment) as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place.

BREACHES OF THIS POLICY

Any employee who breaches this policy may face disciplinary action, which in serious cases could result in dismissal for misconduct or gross misconduct. Thirty-One Circles may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy or fail to comply with their modern slavery obligations under any contractual arrangements with Thirty-One Circles