Modern Slavery and Human Trafficking Statement

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR ENDING 31^st December 2023

Introduction

This statement sets out the steps taken by FullCircle Claims Solutions Ltd to ensure that slavery and human trafficking are not taking place in our supply chains or in any part of our business. Slavery and human trafficking can occur in many forms, such as forced labour, child labour, domestic servitude, sex trafficking and workplace abuse. Given the nature of the work that we do, we believe that there is a low risk of slavery or human trafficking having any connection with our business. We must, however, not be complacent, and all staff have a responsibility to be aware of any risks in our business and in our wider supply chains and report any concerns to senior management.

FullCircle’s business & supply chains

FullCircle Claims Solutions Ltd, provide insurance claims products to support our clients across a wide range of their insurance products and facilities. Our business is based in the UK with our office situated in the heart of the UK financial district of the City of London.

We employed under 10 employees in the 2020 financial year but are aware as a new business that we are growing rapidly therefore take no complacent view of our responsibilities towards Modern Slavery Act of 2015 whilst recruiting new employees.

We ensure that all our suppliers and trading relationships with Lloyd’s Brokers, Underwriters, MGA’s, TPA’s and Service companies as well as non-Lloyd’s entities in the same field are aware of our stance and position towards the Modern Slavery Act of 2015.

FullCircle’s policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We believe in paying people fairly and properly for their work. This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we have put in place the following:

• Identify and assess potential risk areas in our supply chains. We give all suppliers a copy of this statement and request a copy of their statement (if they are required to have one).
• Mitigate the risk of slavery and human trafficking occurring in our supply chains. We set clear expectations for our suppliers by informing them of our Code of Conduct, which states ‘FullCircle does not tolerate modern slavery or any form of human trafficking within its business or supply chains. FullCircle does not allow harsh or inhumane treatment and we expect our suppliers to share our values.’
• Monitor potential risk areas in our supply chains. Staff are encouraged to report any concerns to senior management and there is a risk register operated by the Operational Risk Manager to record any such concerns.
• Ensure appropriate recruitment practices are carried out, using reputable employment agencies. We verify the practices of any new recruitment agency as part of our terms of business with them and before accepting any workers from that agency. We also request a copy of the agency’s modern slavery statement (if it is required to have one). We ask any agency supplying us with staff to conduct verification checks on those staff (including verification of identity, references, evidence of qualifications and criminal and financial checks). We also carry out the same checks on direct hires.
• Protect whistle-blowers. At FullCircle, workers, customers and suppliers are encouraged to report any concerns related to our activities or supply chains. This includes circumstances which may give rise to increased risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for people to make disclosures without fear of retaliation.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will be providing training to appropriate members of staff.

Our commitment

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31 August 2020.

This Modern Slavery and Human Trafficking Statement is reviewed by FullCircle’s Directors at least annually and may be amended from time to time.

This statement was approved by the FullCircle’s CEO 1st November 2024.