Modern Slavery & Human Trafficking Statement

1. Foreword

This statement sets out Clerks Associates UK Ltd actions to understand all potential modern slavery risks related to its activity and to put in place steps that are aimed at ensuring that there is no slavery in its own business and its supply chains.

This statement relates to actions and activities during 2022/2023. Clerks Associates UK Ltd is committed to preventing slavery in its mission to deliver exceptional service to the education sector and to ensuring that its supply chains are free from slavery. As part of the education sector, the organisation recognises that it has a responsibility to take a robust approach to slavery.

Clerks Associates UK Ltd is committed to high standards of ethical and governance arrangements in respect of impartiality, integrity, and objectivity in managing our activities.

Over the next year, we will provide awareness training to all our colleagues on the Modern Slavery Act 2015 and make suitable resources available to enable them to take appropriate action if they suspect a case of slavery or human trafficking. We will also continue to do our own risk assessments and work with our suppliers to help them better understand the anti-slavery activity they should be undertaking. We are committed to maintaining best practice and to seeking continuous improvement.

S Miller – Head of Service. January 2023.

2. Our commitments

Clerks Associates UK Ltd is committed to protecting and respecting human rights and have a zero-tolerance approach towards modern slavery and support the UK Government’s objectives to eradicate modern slavery and human trafficking. We believe that there is a low risk of slavery or human trafficking having a connection with our activities.

We are committed to ensuring that there is no modern slavery and human trafficking in our supply chains or any part of our business. We do not enter into business with any organisation which knowingly supports, or is found to be involved in slavery, servitude or forced or compulsory labour.

As an equal opportunities’ employer, we are also committed to creating and ensuring a non-discriminatory and respectful working environment for our team. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK.

3. Our business and supply chain

Clerks Associates UK Ltd is a private limited company. We provide a range of services to schools/academies across the country. We employ 35 + members of staff/consultants, and all of our operations are currently based in the UK.

4. Our policies

We are committed to doing the right thing by ensuring we respect human rights and the environment. The following policies are available to all staff:

· Code of conduct

· Whistleblowing policy

· Bullying and harassment policy

· Diversity and inclusion policy

· Recruitment and selection policy.

5. Risk Management

As part of our initiative to identify and mitigate risk we have identified the principal areas which carry material risks. Clerks Associates UK Ltd ensures that suppliers are required to demonstrate their methods of corporate social responsibility. Clerks Associates UK Ltd reserves the right to exclude any supplier/client who has been convicted of an offence under the Modern Slavery Act 2015. Suppliers/clients of Clerks Associates UK Ltd are required to fully comply with the Modern Slavery Act 2015 and confirm that they do so by inserting such in their Terms and Conditions.

Our supply chains include:- ICT equipment, office consumables and office equipment. We have in place systems to: Identify and assess potential risk areas in our supply chains. Mitigate the risk of slavery occurring in our supply chains. Protect whistle blowers. We have identified that some of our procurement takes place within sectors where modern slavery offences could occur, such as within our office consumable supply chains.

We will be taking the following steps to promote awareness of this during 2022/2023: Raise awareness amongst teams involved in employment, procurement, and management, of the risks of modern slavery occurring within our supply chains. Include compliance with the Modern Slavery Act as a condition or criterion. Ensure our ‘New Supplier’ form requests all suppliers adhere to the Modern Slavery Act.

Conduct a more in-depth review of our supply chains to better understand the risks of modern slavery occurring within them. Our policies to resist modern slavery,

We have reviewed our existing policies and procedures in light of the Act. We are confident that our policies promote good behaviour among our colleagues at work.

Our policies and procedures are kept under review to make sure that they reflect the changing needs of Clerks Associates UK Ltd and of the staff and the communities it serves.

Among the policies that we consider give us strength in avoiding modern slavery under the Act in Clerks Associates UK Ltd are: – Code of Conduct & Confidentiality Equal Opportunities & Diversity Policy Fraud Policy Recruitment Policy Whistleblowing Policy The whistleblowing policy has been amended to draw attention to the risk of modern slavery and to stress that a report of concern in relation to those matters can be made under the protection of the whistleblowing policy. We are determined that there shall be no modern slavery in Clerks Associates UK Ltd. Our policies evidence our commitment to act ethically and with integrity throughout our organisation.

8. Key performance indicators

Where potential modern slavery impacts are identified within a contract requirement, we will work with our suppliers/clients to develop appropriate KPIs to monitor and manage performance in regard to these risks.

9. Training on modern slavery and trafficking

All procurement team members are also required to undertake mandatory modern slavery awareness training. We will ensure our staff involved in procurement activity are aware of and follow modern slavery procurement guidance from GOV.UK.

10. Fair Pay.

Clerks Associates UK Ltd is committed to ensuring that all directly employed and contracted staff receive fair remuneration for the job they perform. This is demonstrated through our commitment to ensuring staff receive, as a minimum, the National Minimum Wage, set annually by the government.

This commitment means that all staff, whether employed directly, as contractors or through our sub-contractors, receive the appropriate National Minimum Wage.



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