The Modern Slavery Act & Human Trafficking

Although the legislation allows you the freedom to publish a statement that simply explains that you haven’t taken any steps to tackle modern slavery, the obvious risk to your company in this scenario makes this unlikely to be a sustainable long-term position to take. There is a clear opportunity for businesses to show excellence in this area, and provide leadership to the many companies affected by the Act.

The trickle-down effect of larger businesses increasing their scrutiny in relation to modern slavery will impact smaller businesses that are not required to publish their own statement. Clarity Umbrella Ltd has a turnover under the £36m threshold, but has chosen to publish our policy on Modern Slavery and Trafficking.

Supplier Code of Conduct

Clarity Umbrella Ltd supports the protection of human rights around the world. We are guided by fundamental principles such as the International Labour Organisation (ILO) Core Conventions and we comply with necessary regulation, including the UK Modern Slavery Act 2015. We operate in accordance with 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). This support is reflected in our policies and actions in the countries in which we do business.

Clarity Umbrella Ltd seeks to support human rights through our supply chain by encouraging behaviours and practices that are consistent with the objectives of the Clarity Umbrella Ltd Statement on Human Rights.  We welcome relationships with our Suppliers as opportunities to improve and evolve practices with respect to Human Rights. These behaviours and practices consider specifically:

Health and Safety

Provision of a safe and hygienic working environment that minimises health and safety risks and supports accident prevention for all personnel, bearing in mind the prevailing knowledge of the industry, the requirements of local health and safety laws and of any specific hazards.

Freely Chosen Employment

Ensuring that all work is completed voluntarily and without slavery, servitude, forced or compulsory labour and human trafficking.

Avoidance of Child Labour

Child labour should not be employed. The term ‘child’ refers to any person less than 15 years of age (or 14 where the law of the country permits), unless the minimum age for work or mandatory schooling is stipulated as being higher by local law, in which case the stipulated higher age applies in that locality.

Working Hours

Ensuring that all workers are entitled to work and be paid for a minimum level of working hours; that working hours are not excessive; and that maximum working hours comply with national laws.

Wages and Benefits

Being responsible for employee compensation and payment of fair wages. All employees should be paid a fair wage commensurate with prevailing industry conditions or the minimum wage, whichever is higher. Any overtime should be voluntary and compensated appropriately.

Employee Freedom of Association

Respecting the rights of workers in relation to freedom of association. Where the right of freedom of association and collective bargaining is restricted under law, the Supplier will not hinder the development of alternative means for informing/consulting with employees.

Modern Slavery Statement

This statement is made pursuant to s.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 or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Clarity Umbrella Ltd 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

Clarity Umbrella Ltd offer PAYE payroll services to the highly skilled temporary workforce working within the UK for a variety of end clients, the assignments generally tend to be sourced by recruitment agencies who have the direct contact with the end client. Each contractor is employed by Clarity Umbrella Ltd under an over-arching contract of employment.

Over 90% of our employees are based on assignment within business in the UK, with a small percentage providing their services to overseas businesses. 95% of the contractors are assigned to undertake IT work within either the private or public sector.

At any one time, we may have any number contractors on our books working with different end clients, via different recruitment agencies.

Our High Risk Areas

We perform right to work checks on all of our contractors before entering into the B2B contract with the agency or end client, we will also ensure checks are completed before the contract of employment is agreed and any payroll is processed to our employees.

We have very few actual suppliers of goods or services to the business, however we do request copies of their Modern Slavery Statement where appropriate to ensure that we are working with compliant businesses.

We feel there is very little risk associated with our workers and suppliers who generally tend to demand average rates of around £500.00 per day.

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.  This 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. We operate a whistleblowing policy so that 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.

Our Suppliers

Clarity Umbrella Ltd operates a supplier policy and maintains a preferred supplier list.  We conduct due diligence on 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. 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)
• We may terminate the contract at any time should any instances of modern slavery come to light

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Clarity Umbrella’s slavery and human trafficking statement for the current financial year. The statement has been approved by the director, who will review and update it annually. 

Lucy Smith
Clarity Umbrella Ltd

September 2020