Modern Slavery Policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. Preventing exploitation and human trafficking, and protecting Clarks workforce and reputation makes good business sense and supports Clarks Code of Business Ethics principles.

“We treat all employees and each other fairly, with dignity and respect;
We operate with integrity and honesty; and
We base our business relationships on respect; and expect the same from those that we do business with”.

The Modern Slavery Act 2015 (MSA) and the California Transparency in Supply Chain Act 2012 (CTA) recognise the important part businesses can play in tackling slavery and we need to ensure we pay close attention to:

  1. Our supply chain and distribution channels;
  2. Outsourced activity;
  3. Cleaning and catering suppliers;
  4. Corporate hospitality; and
  5. Recruitment (particularly through agencies).

We will:

  • maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation;
  • be clear about our recruitment policy;
  • check our supply chains;
  • lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc to ensure we know who is working for us;
  • ensure we have in place an open and transparent grievance process for all staff;
  • seek to raise awareness so that our colleagues know what we are doing to promote their welfare; and
  • make an annual statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees and our clients seriously.

Clarks have a zero-tolerance approach to modern slavery and we are 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 modern slavery is not taking place anywhere in our own business. Our policy applies to all persons working for us or on our behalf in any capacity, including employees, agents, contractors, external consultants, third-party representatives and business partners.

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the relevant Acts. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

We may, where appropriate, and with the welfare and safety of local workers as a priority, give support and guidance to our suppliers to help them address coercive or exploitative work practices in their own business and supply chains.
The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control.

We will ensure that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Training on this policy, and on the risk our business faces from modern slavery in our supply chain, forms part of the induction process for all individuals who work for us. We provide specialist training to those staff members who are involved in managing recruitment and our supply chains.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, email