This statement sets down how Clarke are commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Clarke 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.
Our Business
We are a specialist facade contractor completing full envelope solutions to clients across the UK and Ireland.
Our high-risk areas
We have identified that our highest risk areas are where we engage labour only contractors and temporary recruitment agencies. Through experience and relationships with our current organisations we are confident that all staff are working in compliance with above legislative requirements.
Our policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
Anti-slavery policy - our policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
Recruitment policy - we operate a robust recruitment policy, 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.
Whistleblowing policy – our policy is in place to ensure all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
Code of business conduct - o u r code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
Our suppliers
At Clarke we operate a supplier policy and maintain a preferred supplier list. We conduct due diligence in regard to all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery and on site audits which include a review of working conditions. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
They have taken steps to eradicate modern slavery within their business.
They hold their own suppliers to account over modern slavery.
(For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate).
(For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations.
We may terminate the contract at any time should any instances of modern slavery come to light.
Training
We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain. All staff are required to participate in training to better understand the risks and content includes ways to identify and report modern day slavery.
Our performance indicators
Clarke uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains:
No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
Feedback from our wages & Finance Dept regarding suspicious activities.
Approval for this statement
Our Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. Our Senior Leadership Team and Board endorses this policy statement and is fully committed to its implementation.
This statement has been approved and authorised by: