1. Introduction

As a specialist IT recruitment agency operating in the UK and EU, Circle Group Ltd recognises the risks of modern slavery in our sector, including:

• Exploitative recruitment practices (e.g., excessive fees charged to candidates)

• Subcontracted labor (e.g., offshore contractors with opaque working conditions).

• Visa-linked exploitation (e.g., sponsored workers forced into debt bondage).

We commit to ethical recruitment and zero tolerance for modern slavery in our operations and supply chains.

2. Our Business & Supply Chain

Scope:

We provide temporary/permanent IT staffing solutions across multiple industries, inc. government, IT, finance

and healthcare.

Risk Areas:

Offshore subcontractors (e.g., third-party recruiters in high-risk regions).

Contractor working conditions (e.g., gig economy roles with poor oversight).

Candidate vulnerability** (e.g., migrant workers on sponsored visas).

3. Policies & Commitments

We enforce:

• Ethical Recruitment Policy: Prohibiting candidate fees and wage deductions.

• Supplier Code of Conduct: Mandating fair wages and safe conditions for subcontractors.

• Whistleblowing Policy: Anonymous reporting via the Safecall platform.

• Right to Work Checks: Rigorous verification to prevent forced labor.

4. Due Diligence in 2025

To mitigate risks, we:

• Audited 95% of partners for compliance with UK labor standards and wage controls.

• Trained 100% of staff on spotting coercion (e.g., any withheld pay).

• Implemented AI tech tools for contractor payroll audits.

5. Future Actions in 2025

Ensuring National Minimum Wage Levels are maintained across clients

Active industry collaboration to lobby for stricter recruitment licensing.

6. Approval

This statement was approved by:

Stephen Ricketts, Managing Director, Circle Group Ltd

Published 12th May 2025 in accordance with the UK Modern Slavery Act 2015