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Clarity Anti-Slavery and Human Trafficking Statement

Sixth Statement 

We provide corporate travel management solutions and taking care of business travellers is our priority. Backed by the brightest people in business travel, we combine state-of-the-art technology with exceptional customer service, attention to detail and duty of care.

This statement sets out Clarity’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement is published in line with section 54(1) of the Modern Slavery Act 2015 and has had full sign off by the Executive Board of Directors.

Our Commitment to the principles of the Modern Slavery Act 2015

We are committed to creating and ensuring an inclusive, non-discriminatory and respectful working environment. We want all our people to feel confident that they can highlight wrongdoing without any risk to themselves.
Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

We do not enter business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Our supply chain

Due to the nature of our business, we assess ourselves to have a risk of modern slavery in our business and supply chains as we procure services from a range of UK and international suppliers.

We have zero tolerance to slavery and human trafficking. We require all supplier and partner organisations we work with to operate to the highest standards both internally and in managing their own supply chains and to share our values and respect for human rights.

We work closely with suppliers, building long term relationships where we can, in order to support our focus on working conditions and quality and we have a formal escalation process in place if serious issues affecting working conditions are found within our supply chain.

We are committed to conducting purchasing activities in a fair, objective and transparent manner that satisfies the requirements of accountability and internal controls including but not limited to our ‘Quality Management’, ‘Environmental’, ‘Ethical Code of practice’, ‘Anti-Bribery’ and ‘Modern slavery and Human Trafficking’ policies which fulfil legal and financial obligations and effectively manages commercial risk.

Emphasis is placed on selecting suppliers and service providers that demonstrate recognisable environmental, sustainable, business integrity along with Corporate Social Responsible (CSR) standards including but not limited to compliance with laws and regulations, respect for human rights, labour working conditions, equal opportunities, health and safety accreditation, maintenance and promotion of information security, fair trade and acceptable corporate ethics.

Our Sound Sourcing Policy and Code of Conduct embodies our commitment to conduct business with integrity, in all our business relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. The code sets out requirements on human and labour rights and we aim to ensure that our suppliers understand and collaborate with the criteria in the Code.

On reviewing our risk of modern slavery in our operation, we have again in 2021 had no reports of any incident in our supply chain (or of any human trafficking offence). We have not had to take any action (termination of contract or otherwise) against any supplier because of the findings of the modern slavery questionnaire or otherwise in relation to modern slavery in this past year.

Our people policies

Our policy library available on the company intranet and provided upon commencement of employment, includes the following policies that recognise human-rights principles: -

Modern Slavery Policy - We have zero tolerance of any threat of physical or sexual violence, harassment or intimidation against employees and their family, or close associates.
Equality, Diversity and Inclusion - All our employees are treated fairly and equally and are paid at least the national minimum wage.
Business Conduct Policy - We have zero tolerance of any threat of physical or sexual violence, harassment or intimidation against employees and their family, or close associates.
Dignity at Work – We provide a working environment that respects the rights of each individual employee and where colleagues treat each other with respect and are treated fairly based on their merits and abilities.
Mental Health – We establish, promote and maintain the mental health and wellbeing of all staff through workplace practices, and encourage staff to take responsibility for their own mental health and wellbeing.
Health and Safety – We ensure so far as is reasonably practicable, the health, safety and welfare of all employees, visitors, contractors, and members of the public who may be affected by our activities.
Anti-Bribery and Corruption - We conduct our business in an honest and ethical manner. Clarity takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships.
Whistleblowing Policy - We encourage all of our employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Clarity. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.

Training and initiatives

We raise awareness of modern slavery issues by ensuring annual mandatory refresher training for all our employees. The training explains the principles of the Modern Slavery Act and how to identify and flag up potential slavery and human trafficking.

In 2020 and 2021, we adapted many employee programmes to meet the needs of remote working during COVID-19. We launched a range of new engagement initiatives. Regular surveys, which we still undertake now, helped us understand the needs of our employees during the pandemic. This helped us continually adapt our strategy, proactively meet everyone’s needs and supporting their ongoing health and wellbeing.

2022 Plans

This is the sixth year of reporting on modern slavery, and we continue to ensure that working conditions for all our employees far exceed the statutory minimum required by law. With over 350 dedicated and hardworking employees we believe that we consistently demonstrate our ethos of being “Brighter” and as an employer of choice.
We continue to be accredited as a Disability Confident employer, have signed the Mental Health at Work Commitment Charter and the Armed Forces Covenant. We are also now a Real Living Wage employer.

Pat McDonagh
CEO of Clarity
January 2022

Click here to read our sixth statement, dated January 2022.
Click here to read our fifth statement, dated January 2021.
Click here to read our fourth statement, dated January 2020.
Click here to read our third statement, dated February 2019.
Click here to read our second statement, dated December 2017.
Click here to read our first statement, dated 28th February 2017.

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