Transparency Statement

Slavery and Human Trafficking Transparency Statement

About Populous
Populous is a global architecture and design firm that designs the places where people love to be together, like Yankee Stadium, the London Olympics, and the Super Bowl. Over the last 40 years, the firm has designed thousands of projects worth over $60 billion across emerging and established markets. Populous’ comprehensive services include architecture, interior design, event planning and overlay, branded environments, wayfinding, and graphics, planning and urban design, landscape architecture, aviation and transport design, hotels and hospitality, and sustainable design consulting.

Populous employs approximately 1,200 employees worldwide and has 30 offices on four continents with regional centers in Kansas City, London, and Brisbane.  All operations, including the services provided in the UK, are ultimately owned by Populous Holdings, Inc., a company incorporated in the State of Delaware, United States.  Populous Limited is a wholly owned subsidiary company of Populous Holdings, Inc., with its registered office in London, United Kingdom. Populous Limited primarily provides its services in the EMEA region.

Our Policies
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We are committed to acting ethically and with integrity in all our business relationships, and we have implemented effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Populous’ Supply Chains and Supplier Adherence to Populous Values and Ethics
As an architecture and consulting firm, Populous considers the risk of modern slavery and human trafficking in its supply chain to be low.  Populous’ supply chains are primarily comprised of professional consultants providing architectural and design related services, as well as key suppliers to provide software, hardware, equipment, and supplies.  That said, Populous has zero tolerance for slavery and human trafficking.  Populous has in place systems to mitigate and monitor potential modern slavery risks in our supply chain. These systems include:

• Perform due diligence on its sub-consultants and suppliers
• Implement and enforce a process for the appointment of competent professionals which includes, where appropriate, a requirement that new sub-consultants/suppliers comply with our standards and procedures
• Require sub-consultants and suppliers to comply with all applicable laws and, where appropriate, to implement due diligence procedures for their own supply chains
• Invest in strong relationships with its sub-consultants, many of whom are of international repute and with whom Populous works repeatedly

Due Diligence for Recruitment and Employment
Our employment processes include verification of the legal right to work in their country of engagement, as well as the implementation of fair and transparent recruitment procedures in accordance with local employment laws.

Training
Employees receive training and are required to periodically certify compliance with Populous policies.  Populous encourages those that work for or on behalf of the company to ask questions concerning compliance and ethical issues and to report suspected violations of the law and/or Populous policies.  Populous maintains an anti-retaliation policy to safeguard those who make such reports.

Further Steps
We continually develop systems, controls and training to ensure that there is no slavery or human trafficking in our supply chains, and we will continue to develop and monitor our supplier and subconsultant relationships, due diligence procedures and, where relevant and appropriate, the introduction of new contractual provisions to ensure compliance with the Modern Slavery legislation. All Populous employees will continue to receive training on ethical conduct, including the issues surrounding slavery and human trafficking.

This statement is made on behalf of Populous and is pursuant to section 54(1) of the UK’s Modern Slavery Act 2015 and Populous’ slavery and human trafficking statement.

The Board of Directors of Populous Holdings, Inc.
Earl Santee, Chair
Richard Breslin
Stephen C. Carver
Shireen Hamdan
Paul Henry
Christopher Lee
Michael Lockwood
Bruce Miller
J. Scott Radecic
Nicholas Reynolds
Jonathan Mallie

2024