Modern Slavery Statement

Slavery and Human Trafficking Statement

This Policy should be read in conjunction with our Corporate Social Responsibility Policy Statement BMS003.

At Perfect Circle, the core principles of our Corporate Social Responsibility (CSR) includes a commitment to improve CSR policies in relation to the communities within which we work, our own people, our supply chain and society as a whole.

Following the enactment of the Modern Slavery Act 2015, this statement builds on our CSR, outlining what we are doing to ensure modern slavery is not occurring in our supply chain and in our own organisation.

Since it was founded in 2016, Perfect Circle's collective expertise has delivered lasting legacies for public sector authorities and communities. Jointly owned by industry leading consultancies Pick Everard, Gleeds and AECOM, we are supported by an extensive supply chain of more than 500 partners, formed of micro businesses, SMEs and larger consultancies, ensuring we can service any project or requirement, anywhere in the UK.

Due to the nature of the business and the fact that our employees are professionals supported by administration and advisory teams, there is no modern slavery in our organisation. All of our employees are paid competitive salaries matching their professional qualifications and experience.

Perfect Circle has taken steps to ensure that modern slavery is not occurring in our supply chains and in our organisation.

Due diligence process:

Perfect Circle Business Management System (PC BMS) Procedure for the procurement of supply chain has been amended so that the engaging party is required to check that there is no modern slavery in the procurement of our supply chain.

The Assessment and Management of Supply Chain procedure has been updated and is the process whereby we ensure that potential supply chain comply with the Modern Slavery Act. It is validated through an approval process within Perfect Circle.

We have now included checks; for organisations that have a turnover of above £36 million, we verify if the organisation has published a Slavery and Human Trafficking Statement on its website. For organisations that are not subject to the Modern Slavery Act, we require the director/proprietor/partner to make a statement that its organisation is compliant with the National Minimum Wage Act 1998 and that it does not engage in Modern Slavery and Human Trafficking. This is part of the assessment process with Modern Slavery being reviewed at each stage of the approval and appointment process.

Any risks associated with our supply chain, including suppliers Modern Slavery risks, will be mitigated at approval stage and reviewed continuously as part of our risk management process. Where appropriate, we will work with organisations to prevent activities and practices that support modern slavery.

We have processes in place to report any suspected instance of modern slavery.

Perfect Circle will not support or deal with any business knowingly involved in slavery or human trafficking.

Key Performance Indicators are used to measure progress in tackling modern slavery.

We ensure all employees are aware of the Modern Slavery and Trafficking Act by raising awareness during any relevant training and PC BMS.

The implementation and operation of the PC BMS underlines our commitment to this policy. Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached.

This statement is made pursuant to Section 54, of the Modern Slavery Act 2015.

All our policies and procedures are made available and communicated to all of our employees as well as our partners and supply chain.

This policy will be reviewed annually as a minimum.

Signed for on behalf of Perfect Circle:

Victoria Brambini

Managing Director

Policy BMS 005, Issue 10 | March 2023