Common Legal Circle (CLC)
Date: 17/05/2023

1. Introduction

Common Legal Circle (CLC) is committed to ensuring that modern slavery human trafficking, forced labor and exploitation have no place in our organization or supply chain.

As a legal entity we uphold the highest ethical standards and comply with all relevant legal obligations including the Modern Slavery Act 2015 (UK) and international human rights laws. We take a zero-tolerance approach to modern slavery and implement proactive measures to mitigate risks and promote ethical practices in our operations and business relationships.

2. Purpose

The purpose of this policy is to:

• Establish a clear framework to prevent and address modern slavery risks.
• Ensure compliance with all applicable laws and ethical standards.
• Promote transparency, accountability and due diligence in our operations.
• Provide employees, partners and stakeholders with guidance on recognizing and reporting concerns related to modern slavery.

3. Scope

This policy applies to: - All employees, partners and associates of CLC.

• All suppliers, contractors and third-party service providers engaged by CLC
• Any business relationships or networks associated with CLC’s operations.

4. Policies & Governance

To reinforce our commitment CLC has implemented the following policies and procedures:

• Code of Conduct: Outlines expected ethical behavior for employees, clients and business partners.
• Supplier &Third-Party Compliance Policy: Requires all suppliers and contractors to comply with anti-slavery laws and ethical labor practices.
• Whistleblowing Policy: Provides a confidential channel for reporting modern slavery concerns without fear of retaliation.
• Recruitment & Employment Policy: Ensures fair and transparent hiring practices preventing forced labor and exploitation.

5. Risk Assessment & Due Diligence

CLC proactively identifies and mitigates modern slavery risks through:

• Risk assessments across our operations and supply chains.
• Supplier audits and legal reviews to ensure compliance with ethical standards.
• Contractual obligations requiring suppliers and partners to adhere to anti-slavery laws.
• Ongoing monitoring and improvement of due diligence processes.

6. Training & Awareness CLC is committed to raising awareness about modern slavery by:

• Providing mandatory training for employees, management and key stakeholders.
• Conducting awareness campaigns to help employees recognize and report signs of exploitation.
• Engaging with industry bodies and legal organizations to stay informed on best practices.

7. Reporting & Compliance

CLC encourages employees, clients and stakeholders to report any concerns regarding modern slavery through our confidential reporting system. We commit to:

• Investigating all reports promptly and thoroughly.
• Taking corrective action where necessary including terminating relationships with non-compliant suppliers or partners.
• Ensuring all reports arehandled with confidentiality and protection from retaliation.

8. Continuous Improvement CLC is dedicated to strengthening its approach to modern slavery prevention by:

• Regularly reviewing and updating this policy.
• Improving transparency in our business operations.
• Strengthening collaboration with industry experts and human rights organizations.
• Enhancing our supplier due diligence framework.

9. Review & Approval

This policy has been approved by [Name], [Position] on [Date] and will be reviewed annually to ensure continued effectiveness and compliance.

Jaswant Singh

Common Legal Circle (CLC)

Date:17/05/2023