Introduction

Modern slavery and trafficking are heinous crimes and morally reprehensible acts that are a real yet hidden issue in our society. This affects millions of people globally, including many in developed countries, who are being kept and exploited for various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.

At Clarasys, we are committed to acting ethically and with integrity with a zero-tolerance policy to any form of modern slavery and child labour. The following statement sets out the steps Clarasys Ltd has taken in relation to our responsibilities under Section 54, Part 6 of the UK Modern Slavery Act 2015 (“MSA”) to ensure that slavery and human trafficking is not taking place in any part of our business or our supply chains.

Our business

Clarasys is a management consultancy headquartered in London, UK, with an office in Boston, USA. As the ‘experience consultancy’, we believe in a better way of doing business consultancy; working closely with our clients to ensure we understand their business as well as we understand our own. We aim to leave our clients with the knowledge to enable rapid and sustainable change. Everything we do at Clarasys is focused on creating engaging, smart-working and connected experiences that increase efficiency and dependability, loyalty and reward. We provide services to a range of private and public sector organisations, as well as not-for-profit organisations.

Our supply chains

We believe the nature of what we do at Clarasys means the risk of human trafficking or slavery occurring in our business or our supply chains is low, with the majority of products and services sourced from suppliers based in the UK. However, we have a zero-tolerance approach to modern slavery. We are fully committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that any form of slavery is not taking place in our own business or supply chains.

Managing risk

Discrimination and harassment policy: We have zero-tolerance of any threat of physical or sexual violence, discrimination, harassment or intimidation against employees. Our policies are clearly defined and communicated to all employees. All our employees are treated fairly and equally and are paid at least the national living wage including those contracted through facilities partners.

Recruitment policy: Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK or the US (as applicable) so as to safeguard employees from any abuse or coercion.

Speak up policy: We organise our company around a set of structures and principles that ensure employees are able to voice their concerns about how colleagues are being treated, or suspicious practices within our business or supply chain, without fear of reprisal. This is done by ensuring there are multiple channels of communication for our people – everyone has a coach they speak to weekly, an HR People Partner who engages with them on a regular basis, feedback surveys where people can raise concerns and we regularly discuss the theme of ‘Behaviour that is counter to our values’ in coaching and business-wide forums. We pride ourselves on having a culture that prioritises trust and safety through all our processes and decisions, and if anything of concern is raised it is fully investigated and appropriate resolutions are actioned.

Code of conduct: We have a long-standing commitment to conducting business in a responsible way and in accordance with our code of conduct which endeavours to avoid causing any adverse impact on the human rights of our both employees and our wider stakeholder network.

Anti-bribery and corruption policy: Our anti-bribery and corruption policy outlines the responsibilities of Clarasys and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.

Our commitment

We intend to take the following steps in 2022 to mitigate risk of slavery and human trafficking:

  • Improving our purchasing policy which will include a procurement framework and code of ethics. This will ensure that Clarasys is committed to conducting purchasing activities in a fair, objective and transparent manner that satisfies the requirements of accountability and yet fulfils legal and financial obligations and effectively manages commercial risk.
  • We are passionate about doing business responsibly and acting ethically in our business conduct. We will work closely with our partners and suppliers to ensure they share our commitment to human rights and the prevention of Modern Slavery and Child Labour within their businesses and supply chains.
  • We will not work with clients, partners and suppliers who are deemed to be in violation of the Modern Slavery Act or Child Labour laws.

Signature

This statement has been approved by Matt Cheung, CEO for the financial year ending Dec 2021.

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