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Anti-Slavery & Human Trafficking Statement

  1. Introduction

It continues to be a priority for Two Circles to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and in our supply chain. This statement highlights we are fully aware of the content of the Modern Slavery Act 2015, including offences under that Act. We understand that modern slavery refers to the illegal practices of slavery, servitude, forced or compulsory labour and human trafficking.

  1. Organisation’s structure

We are a London-headquartered global provider of services In the sports and entertainment sector. We have over 1000 employees worldwide and our ultimate parent company is Taurus International Holdings Limited.

  1. Due diligence processes for slavery and human trafficking

We have appropriate policies and processes in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

We confirm that we are taking the following steps to achieve a modern slavery-free business and supply chain:

  • committing to acting ethically and with integrity in all our business relationships;
  • implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains and recruitment practises, consistent with our obligations under the Modern Slavery Act 2015;
  • protecting whistleblowers; and
  • as part of our supplier engagement processes: confirming our suppliers’ commitments to human rights principles (amongst various other ethics-related principles); and including specific contractual prohibitions regarding compliance with applicable law (including prohibitions against slavery, servitude and the use of forced, compulsory or trafficked labour).
  1. Relevant business contacts

See below for the relevant Two Circles contact who will all be happy to help with any queries in respect of Anti-Slavery and Human Trafficking:

Joe Tompkins

Joe.Tompkins@twocircles.com

Bedford Thomas

Bedford.Thomas@twocircles.com

 

5. Breaching This Policy

Breaching this policy may result in disciplinary actions (including dismissal) in accordance with our disciplinary procedure and your employment contract.

If you’re concerned about someone else actually or potentially breaching this policy, please notify your manager or the contact in the Section 4 table immediately and this shall be handled in a confidential and appropriate manner.

6. Changes to This Policy

This policy is a working document and is subject to change. Employees will be notified of changes and it will be employees’ responsibility to read the latest versions once published.

DOCUMENT CONTROL

Version

Author/Editor

Change

Review/Approver

Date

1

Legal

Document Creation

Joe Tompkins, Matthew Taylor, Charlie Kendrick

16/10/2025

2

Legal

First Review

Matthew Taylor, Kamae Allen

30/06/2026

**

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 2025. It was approved by the board of Two Circles Limited on 30 June 2026.

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