The Modern Slavery Act – Modern Slavery and Human Trafficking Statement
Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps that Clarity Umbrella Ltd has taken, and is continuing to take, to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.
Modern slavery encompasses slavery, servitude, forced or compulsory labour, and human trafficking. Clarity Umbrella Ltd has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all business dealings. We are committed to implementing effective systems and controls to safeguard against any form of modern slavery within our operations and supply chain.
This statement covers the financial year ending April 2025
Clarity Umbrella Ltd meets the reporting threshold of £36 million global turnover as required under the Modern Slavery Act 2015.
Our Business
Clarity Umbrella Ltd provides PAYE payroll services to highly skilled temporary workers operating primarily within the United Kingdom across a variety of end clients. Assignments are typically sourced through recruitment agencies that maintain direct relationships with end clients.
Each contractor is employed by Clarity Umbrella Ltd under an overarching contract of employment. The majority of our workforce operates within professional services environments, predominantly within IT roles across both private and public sector organisations.
Our Commitment to Human Rights
Clarity Umbrella Ltd supports the protection of human rights globally. Our approach is guided by internationally recognised standards, including:
International Labour Organisation (ILO) Core Conventions
The International Bill of Human Rights, comprising:
the Universal Declaration of Human Rights (UDHR),the International Covenant on Economic, Social and Cultural Rights, and
the International Covenant on Civil and Political Rights.
These principles are reflected in our internal policies and the expectations we set for suppliers and business partners.
Supplier Code of Conduct
We seek to support human rights throughout our supply chain by encouraging behaviours and practices consistent with our Human Rights commitments. We view relationships with suppliers as opportunities to continuously improve standards relating to ethical working practices.
Our expectations include:
Health and Safety
Provision of a safe and hygienic working environment that minimises health and safety risks and supports accident prevention, taking account of industry knowledge and applicable local laws.
Freely Chosen Employment
All work must be voluntary and free from slavery, servitude, forced or compulsory labour, and human trafficking.
Avoidance of Child Labour
Child labour must not be used. A child is defined as any person under 15 years of age (or 14 where permitted by local law), unless a higher minimum age applies.
Working Hours
Working hours must comply with national laws, must not be excessive, and workers must receive appropriate rest periods.
Wages and Benefits
Employees must receive fair wages meeting at least legal minimum standards or prevailing industry benchmarks, whichever is higher. Overtime must be voluntary and appropriately compensated.
Freedom of Association
Suppliers must respect workers’ rights to freedom of association and collective bargaining or facilitate alternative lawful mechanisms for employee consultation where restrictions apply.
Risk Assessment
While the nature of our business model presents a comparatively lower exposure to modern slavery risks than labour-intensive sectors, we recognise that risks may still arise. We therefore maintain proportionate controls to identify, assess and mitigate potential risks.
Risk considerations include:
onboarding and right-to-work verification for all employees;
engagement through regulated recruitment agencies;
limited use of high-risk supply chains; and
ongoing monitoring of supplier compliance.
Our Policies
We operate internal policies designed to promote ethical and transparent business practices, including:
Anti-Slavery Policy – outlining our stance on modern slavery and guidance on identifying and reporting concerns.
Recruitment Policy – incorporating eligibility-to-work checks and safeguards against exploitation or forced labour.
Whistleblowing Policy – enabling employees to raise concerns confidentially and without fear of retaliation.
These policies are reviewed periodically to ensure continued effectiveness.
Our Suppliers
Clarity Umbrella Ltd operates a supplier approval process and maintains a preferred supplier list. We conduct proportionate due diligence prior to onboarding suppliers, which may include:
review of supplier policies and public statements;
risk-based background screening;
contractual commitments relating to anti-slavery compliance; and
periodic reassessment where appropriate.
Suppliers are required to confirm that:
they take steps to prevent modern slavery within their operations;
they hold their own suppliers accountable;
UK-based workers are paid at least the applicable National Minimum Wage or National Living Wage; and
we may terminate contracts where breaches relating to modern slavery are identified.
Our Anti-Slavery Policy forms part of supplier contractual arrangements.
Training and Awareness
We promote awareness of modern slavery risks among relevant staff and ensure employees understand how to identify and report potential concerns through internal reporting channels.
Effectiveness and Ongoing Commitment
We assess the effectiveness of our approach through periodic policy reviews, supplier oversight and internal governance processes.
During the next reporting period, Clarity Umbrella Ltd will continue to:
review supplier due diligence procedures;
maintain awareness of evolving modern slavery risks;
review internal policies annually; and
strengthen proportionate monitoring controls where appropriate.
Approval
This statement was approved by the Board of Directors originally on 01/10/2019 and at subsequent dates moving forwards.
Signed:
Lucy Smith, Managing Director
This statement will be reviewed and updated annually.
Review Date: 01/08/2020
Review Date: 07/08/2021
Review Date: 08/08/2022
Review Date: 09/08/2023
Review Date: 01/09/2024
Review Date: 01/09/2025
For more information on the Modern Slavery Act please visit https://www.gov.uk/government/collections/modern-slavery#full-publication-update-history.