This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Encirc Limited (Encirc) has taken and is continuing to take for the financial year ending 31st March 2025 to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.

Encirc has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

The following key principles apply to our business and suppliers:

(a) Child labour must not be used and we and our suppliers must not benefit from child labour.

(b) Any form of forced or compulsory labour must not be used and we and our suppliers must not benefit from forced or compulsory labour. Workers must be free to leave employment or work after reasonable notice.

(c) Passports should not be taken from workers.

(d) All forms of debt bondage are prohibited. Workers should not be subject to contracts that tie them into repaying a loan, accommodation or some other costs that they have little opportunity to repay.

(e) Compensation and benefits must comply with fundamental principles relating to minimum wages, overtime hours and legally mandated benefits.

(f) The formation of trade unions and powers of collective bargaining should be respected in keeping with the applicable legislation of the jurisdiction in question.

(g) Workers should have safe and healthy working conditions that meet or exceed applicable standards for occupational safety and health.

Encirc are the only company to offer a full service throughout the supply chain, saving time, money and effort. Based at three sites; Derrylin, Fermanagh, Northern Ireland; Elton, Cheshire, UK, and The Park, Bristol, UK we offer three services providing our customers with a single solution. We offer container glass manufacturing, filling and logistics, a unique service offering in our field.

Encirc is committed to delivering high standards of corporate governance and we aim to employ the highest ethical and professional standards and always to comply with all relevant laws and regulations applicable to our business.

Encirc is committed to preventing slavery and human trafficking in its corporate activities and its supply chains. This commitment is supported by our employee training programmes and company policies. We also expect the same high standards from those parties with whom we engage, such as our suppliers and customers.

Encirc have a comprehensive values-based behavioural framework, which sets out the standards required of employees, including the importance of ethics and integrity.

Employees are encouraged to report any perceived unethical behaviour to either their manager or a member of the HR team.

Encirc are committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. Suppliers will be supplied with this policy and required to comply with the same.

We have a zero-tolerance approach to modern slavery and human trafficking and thereby expect all our direct and indirect suppliers/contractors to follow suit. We will work towards ensuring that all of our key supplier contracts contain an anti-slavery clause. This clause will contractually prohibit suppliers and their employees from engaging in slavery or human trafficking.

Encirc Limited, a subsidiary of the Vidrala Group, has been a member of SEDEX (Supplier Ethical Data Exchange) since 2007. SEDEX is a not for profit membership organisation with the purpose of driving improvements in supply chain standards and ethical and responsible business practices.

Encirc Limited has been audited by The Supplier Ethical Data Exchange (SEDEX), the SMETA audit (SEDEX Members Ethical Trade Audit) has attested Encirc’s conformity to international and national standards and to Ethical Code (ETI Code). The Audit methodology employed is based on SMETA version 6.0, 2 and 4 pillar system which comprises of;

SMETA 2 – Pillar Audits against a Human Rights framework and the Ethical Trading Initiative (ETI) Base code, Local Law, Health & Safety and Labour Standards plus the Additional Elements of;

• Universal Rights covering UN Guiding Principles (UNGP).
• Management Systems
• Entitlement to work
• Subcontracting & homeworking

SMETA 4-Pillar Audits in addition to above, assessments of Environment and Business Ethics.

Encirc Limited is audited to SMETA 4-Pillar, and audits are conducted by independent and approved auditing companies. All audit reports are uploaded to the SEDEX platform and are shared with full transparency of standards and protocols used.

As part of our process to identify and mitigate risk:-

• Staff must contact and work with the Purchasing department when looking to work with new suppliers so appropriate checks can be undertaken;
• Where possible, we build long term relationships with all of our suppliers;
• We review arrangements with existing suppliers to ensure continued compliance with this policy.
• We randomly request that suppliers provide details of their supply chain;
• The Supplier Audit Checklist includes a section on Modern Slavery; and
• We complete regular audits on our premises on Health, Safety and Environmental matters

Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains;
• monitor potential risk areas in our business and supply chains;
• reduce the risk of slavery and human trafficking occurring in our business and supply
  chains; and

To achieve these aims we operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Purchasing Policy committing Encirc Ltd and every individual involved in purchasing and supply management processes within the organisation, to use their best endeavours to ensure that our purchasing and contracting activities are legal and ethically, environmentally and socially responsible
• Anti-Bribery and Corruption Policy to ensure compliance with applicable legislation including the Bribery Act 2010
• Recruitment Policy – We have a comprehensive and robust recruitment and selection procedure, fully compliant with all relevant legislation, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
• Equal Opportunities. We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities
• Respect in the Workplace Policy to ensure all employees are treated with dignity and respect at work.

Employee Wellbeing

At Encirc we are committed to our employees wellbeing. We believe in:

• Promoting good health and physical wellbeingEmotional health and wellbeing
• Training volunteers to become Mental Health First Aiders
• Encouraging health and wellbeing champions
• Raising awareness of available tools and resources that assist our employees to gain the necessary wellbeing support they require

We also offer all employees access to a comprehensive “my Benefits” platform which provides access to wellbeing support, employee assistance programme and leisure/financial benefits

Employee Engagement

We want to ensure our employees are happy in both their work and workplace environment and we regularly seek employee feedback in terms of employee engagement surveys. In 2023 all of our sites participated in the Great Place to Work Survey, with our commitment to attain Great Place to Work status across all of our sites. We are fully committed to making positive improvements across our sites based upon the anonymous feedback and we have comprehensive action plans to track our progress.

We are looking at ways to continuously increase awareness within our organisation, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and in our business, our key purchasing staff have undertaken and passed the e-Learning Course “Ethical Procurement and Supply” offered by the Chartered Institute of Purchasing and Supply.

This helps them to understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.

We may terminate our relationship with other individuals and organisations if they breach this policy.

The Directors are responsible for monitoring compliance with our Modern Slavery Statement.
This statement is reviewed and updated annually.