Version: June 2023

Introduction

We are committed to taking all appropriate steps to combat slavery and human trafficking. We take a risk-based approach to ensure that our policies and procedures are truly effective on an ongoing basis. These are regularly reviewed to ensure continued compliance within our organization and across our supply chain.

Organization's structure

We are a provider of recruitment process outsourcing services and ancillary human resource and consulting services across multiple sectors. We are a part of the Cielo Group of companies and our parent company is Cielo Inc, which has its head office in the United States. We have 3,600 employees worldwide, 300 of which are in the United Kingdom, and operate in 113 countries.

Our supply chains

Our supply chains include recruitment suppliers, technology providers and suppliers of payroll services, as well as cleaners and suppliers of office equipment.

Our 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. This Anti-slavery and Human Trafficking Policy 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 in place systems to:

• Identify and assess potential risk areas in our supply chains, via due diligence questionnaires and regular audits.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains, via regular audits and the inclusion of anti-slavery clauses in our supply contracts.
• Monitor potential risk areas in our business and our supply chains, via regular risk assessments and audits.
• Protect whistle-blowers.

Supplier adherence to our values

To ensure all those in our supply chain and our contractors comply with our values, we require all suppliers to complete our due diligence questionnaire and to agree to regular audits. All our supplier contracts contain clauses requiring our suppliers to adhere to the principles outlined in our Anti-slavery and Human Trafficking Policy.

Business awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we deliver awareness training to all employees, publish our Modern Slavery Policy on the staff intranet, and send regular communications to our staff on business ethics.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 31, 2023.

Marissa Geist
Cielo, Inc.
Date: June 29, 2023