Anti-Slavery and Human Trafficking Statement 2019

Introduction

This statement is made on behalf of the UK company – White Clarke Technologies Limited, hereafter referred to as “WCT” to address section 45 (1) of the Modern Slavery Act 2015. 
Registered office: 10 Queen Street Place, London, EC4R 1AG. 


WCT is committed to continually improving its practices to combat slavery and human trafficking and has zero tolerance of modern slavery in all its different forms both in its business and in its supply chain. 


This is our first modern slavery statement following the introduction of the Modern Slavery Act 2015. WCT, having an annual turnover of less than £36m, is not subject to section 54(6) of the Act but, as a responsible supplier and employer, the Company chooses to define the following anti-slavery and human trafficking statement for the financial year ending on 31 December 2018. 


WCT aims to be transparent about its approach to modern slavery and this statement outlines its approach to tackling modern slavery, where it can. 

Our business – Structure, Business and Supply Chains

White Clarke Technologies Limited is both a holding and operational company specialising in the provision of technology and software solutions, programmes, business management, IT services and consultancy services to the automotive industry, operating internationally. The Company is focused and committed to working with automotive manufacturers, distributors and their dealer networks. Delivering proven, innovative solutions across more than 30 countries. 


WCT operates in Europe, Africa, Asia, Australasia, North and South America, with its head office of operations located in the UK.

Supply Chain Management

As a software and professional services provider WCT does not have a supply chain (local or international), where modern slavery or human trafficking would be a risk, generally contractors and suppliers used by WCT are therefore not likely to be susceptible to this risk. 


WCT is committed to acting ethically and with integrity in all its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere in the business or supply chains. 

Policies in relation to Slavery and Human Trafficking

WCT’s policy to this effect is being included in its new Employee and Sub-Contractor Handbooks, within:
•    the Corporate social responsibility statement
•    the Anti-Bribery and Corruption policy
•    our Equal Opportunities policy
Employee’s access these polices via our internal systems and are re-published when any changes are made. 

Identified risks and steps taken to prevent and manage the risks

WCT is currently in the process of reviewing the anti-slavery systems and controls to:
•    Identify, assess and monitor potential risk areas in the supply chains
•    Mitigate the risk of slavery and human trafficking occurring in the supply chains across the global entity
•    WCT plan to develop a specific modern slavery policy and include in all global handbooks
•    WCT is establishing a Whistleblowing policy to encourage its employees to speak up and report any wrongdoing
This will support existing policies setting out the WCT’s approach to being inclusive and diverse, employee well-being and employee consultation and engagement. 

Due Diligence process for Slavery and Human Trafficking in our Business and Supply Chains

As part of our focus to identify and mitigate risk:
•    WCT will continue to monitor and assess potential risks across the business and our supply chains
•    Procurement and sales teams will include risk assessments as part of their processes and will report any potential risks
•    Implementation of a Whistleblowing policy & protection for whistle blowers
•    Implementation of a Modern Slavery policy in all handbooks

Recruitment and Selection

WCT follows a clearly defined recruitment and selection process ensuring that only reputable agencies or other sources are used to help identify future employees. 


All subsidiaries of WCT will help to ensure appropriate controls are in place to enable employees have the right to work and are therefore protected by relevant employment legislation, including but not limited to checking ‘right-to-work’ documentation, visas and passports. 

Effectiveness in combatting Slavery and Human Trafficking

WCT understands that it has a responsibility to continue to assess and mitigate the risk of modern slavery. While WCT continues to make progress in this area, future developments will be to understand the nature of that risk, establish policies and implement controls to manage any risk that arises. 
WCT aims to:
•    Extend the modern slavery training to all employees
•    Monitor best practice perspectives and approaches to modern slavery, including those of WCT’s customers, and to help ensure WCT are in line with these approaches, where applicable to its business 

Training on slavery and human trafficking

Training on slavery and human trafficking
•    Detailed training updates to all relevant personnel within the procurement/sales teams
•    Updates to our internal training platform to broaden knowledge of this critical area amongst all global employees

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31 December 2018.