Circadian Limited (the “Company”)
Modern Slavery and Human Trafficking Statement

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It takes various forms, all of which have in common the deprivation of a person’s liberty by another in order to exploit them, very often for personal or commercial gain – it is a gross violation of fundamental human rights.

The Company recognises that it is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chains.

The Company recognises that a sector in which there is a particular vulnerability to modern slavery is the construction sector. The Company has zero-tolerance for modern slavery and is fully committed to preventing modern slavery and human trafficking within its practices. The Company understands its responsibility to be alert to the risks, however small, in its business and in the wider supply chain. The Company is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains.

The Company’s business is as follows:

• The Company is a Property Developer
• The Company’s registered office is in Battersea
• The Company’s development and construction site is in Chelsea
• The Company’s supply chains are with suppliers who provide goods and services

The Company seeks to establish a relationship of trust and integrity with all its suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

The Company conducts due diligence as part of its initiative to identify and mitigate risks. Due diligence is conducted on all new suppliers and on existing suppliers on a regular basis, which includes:

• Assessing risks in the provision of their services to us by using a set of criteria
• Monitoring our suppliers on their health and safety standards
• Requiring our suppliers to agree in their services/supply contracts with us to comply with the Modern Slavery Act 2015
• Sanctioning suppliers that fail to improve their performance in line with our requirements

The Company has not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers.

The Company ensures that all current staff have completed an anti-modern slavery training course, and the same course is a mandatory requirement for all incumbent staff.

The Company is a member of the CK Asset Group and complies with the Group’s Human Rights Policy and Supplier Code of Conduct.

This statement covers the period 01 April 2022 to 31 March 2023 and was approved by the Company’s board of directors.