MODERN SLAVERY ACT STATEMENT

Introduction

Barclay Simpson is committed to upholding equality in the workplace and ensuring compliance with all relevant laws and regulations, including the Modern Slavery Act 2015. While we operate within cyber security, risk, and corporate governance recruitment and business solutions consultancy — sectors not typically associated with high risk for modern slavery — we remain vigilant in ensuring that there are no instances of slavery or human trafficking in our business or supply chains.

Structure of the Organisation

Barclay Simpson is a privately owned and managed UK-based recruitment and executive search consultancy. Our head office is in London, with additional offices in Frankfurt, Germany and Austin, Texas. The business includes Barclay Simpson Associates Limited and Barclay Simpson Solutions.

We provide permanent recruitment and interim contract services across the commercial, banking, financial services, professional services, and public sectors. Our services are delivered through specialist divisions in:

• Cyber Security and Resilience
• Data Privacy
• Internal and IT Audit
• Risk Management
• Compliance & Financial Crime
• Legal & Company Secretarial

Our Supply Chains

Our supply chains primarily consist of sourcing candidates and independent contractors for placement in permanent and interim positions with clients, and deploying a blend of permanent staff and associates on business solution projects. Although our exposure to modern slavery risks is limited, we remain vigilant to any potential risks and take appropriate steps to mitigate them.

Staff involved in supplier engagement are required to communicate our zero-tolerance approach to modern slavery and uphold human rights standards. Our standard terms of business with suppliers and contractors include contractual obligations to adhere to the Modern Slavery Act.

Due Diligence Processes

As part of our service to clients, we may supply temporary personnel. We have procedures in place to ensure that all such personnel:

• Have the legal right to work in the UK.
• Have their own bank account for payment.
• Are not subject to coercion and can leave their assignments with reasonable notice.

We maintain a Whistleblowing Policy that enables employees to report concerns in good faith, with protection from retaliation.

Risk and Compliance

Given the nature of our business and client base, we consider our sector to be low risk for modern slavery. However, we will continue to assess this annually and adjust our procedures if necessary to maintain effective oversight.

Training and Key Performance Indicators

Due to our low exposure to modern slavery risk, no formal training or key performance indicators (KPIs) have been implemented to date. We will continue to assess the need for targeted training and KPIs in light of any changes to our business model or risk profile.

Ongoing Commitment

Barclay Simpson is committed to continuous improvement and transparency in combating modern slavery. We will review this statement and our supporting processes annually, or more frequently if required by legislative or operational changes.

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2024.

 Approved by the Board of Directors

 Ian Coyle, Chairman

16/01/2025