Modern Slavery Statement

Effective date: July 2026

Organisation: Circlr Limited

Registered Office: Cavendish House, 18 Queen Street, St. Helier, Jersey, JE2 4WD

Jurisdiction: Jersey, Channel Islands

Last Updated: July 2026

1. Our position

Modern slavery, including forced labour, human trafficking, debt bondage, forced marriage, and child labour, is a violation of fundamental human rights. circlr is committed to acting ethically and with integrity in all of our business dealings and relationships, and to ensuring that modern slavery has no place in our own business or anywhere in our supply chain.

Our company values shape how we work day to day, and this statement is an extension of them. Every member of the team shares responsibility for identifying, preventing, and raising concerns about practices that could put people at risk of exploitation. We believe in work that is freely chosen, fairly rewarded, and carried out with dignity, and we expect the same of everyone we work with.

2. Our business

circlr is a software company based in Jersey, providing asset register and resource planning software. Our team works in professional, salaried roles, and the nature of our business as a software company means the risk of modern slavery occurring within our direct operations is low. We recognise, however, that low risk is not no risk, and that our responsibility extends to the suppliers and partners we choose to work with.

3. Fair employment

All employment at circlr is voluntary, all employees are free to leave with reasonable notice, and no employee is ever required to surrender identity documents or pay fees to obtain or keep their job. We are committed to fair and transparent employment practices, including structured and consistent hiring processes, clear written terms of employment for every role, and regular performance and progression reviews.

4. Policies and awareness

circlr maintains an Anti-Slavery Policy as part of our employee handbook. The policy defines modern slavery, sets out what employees should look for, and explains how to raise a concern, including how to do so confidentially. All employees are required to read and confirm their understanding of our handbook policies when they join the company and annually thereafter. Any concern raised in good faith will be taken seriously and investigated, and no one will suffer any detriment for raising one.

5. Our supply chain and due diligence

As a software business, our supply chain consists primarily of technology vendors, cloud infrastructure and hosting providers, software sub-processors, and professional services firms. We expect every supplier, sub-processor, and contractor we work with to share our commitment to the ethical treatment of workers and to comply with all applicable laws in their jurisdiction, including the UK Modern Slavery Act 2015 where it applies. We review new suppliers before engagement and reserve the right to terminate our relationship with any supplier found to be in breach of our standards.

6. Review

This statement is reviewed annually and approved by circlr's leadership.