Modern Slavery Statement

1. Introduction

This Modern Slavery Statement is made pursuant to Section 54, Part 6 of the UK Modern Slavery Act 2015 and sets out the steps that ClarLabs 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, human trafficking, and forced labor. ClarLabs 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 chains.

This statement covers the activities of ClarLabs for the financial year ending March 31, 2025, and has been approved by the Board of Directors.

2. Organizational Structure, Business & Supply Chains

Our Business

ClarLabs is a UK-based provider of security, compliance, and Azure cloud management solutions. Established in 2018, we operate primarily in the information technology and cybersecurity sectors, offering services to organizations of all sizes across various industries including financial services, healthcare, technology, and the public sector.

Our headquarters are located in London, UK, with additional offices in Manchester, UK and Amsterdam, the Netherlands. We currently employ approximately 85 full-time staff members across these locations.

Our Supply Chains

As a provider of technology services, our supply chains are relatively limited but include:

• Technology providers: Cloud hosting services, software licenses, and hardware suppliers
• Professional services: Consultants, trainers, and other specialist service providers
• Operational suppliers: Office equipment, facilities management, and other business services
• Marketing and sales: Digital marketing agencies, event organizers, and promotional materials suppliers

The majority of our suppliers are based in the UK, EU, and North America, with some technology services sourced globally. We recognize that no supply chain can be considered entirely free from the risk of modern slavery, and we take our responsibility to ensure ethical business practices seriously throughout our supply network.

3. Policies on Modern Slavery

We have implemented the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Anti-Slavery and Human Trafficking Policy

Our dedicated policy outlines our zero-tolerance approach to modern slavery, our commitment to acting ethically, and the expectations we have of our employees and suppliers. This policy:

• Defines what modern slavery encompasses
• States our commitments to preventing modern slavery
• Outlines responsibilities for implementation and compliance
• Provides guidance on reporting concerns
• Details the consequences of policy violations

Supplier Code of Conduct

This code sets out the minimum standards we expect from all suppliers regarding labor practices, human rights, environmental standards, and business ethics. The code:

• Explicitly prohibits the use of forced, bonded, or child labor
• Requires compliance with local labor laws and international standards
• Mandates fair working conditions, including reasonable working hours and fair wages
• Requires suppliers to assess and address modern slavery risks in their own supply chains

Whistleblowing Policy

Our whistleblowing policy encourages all employees, customers, and other business partners to report any concerns related to our direct activities or our supply chains. 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 workers to make disclosures without fear of retaliation.

Ethics and Compliance Policy

This policy outlines our broader commitment to ethical business practices, including our stance on modern slavery. It provides a framework for ethical decision-making that all employees are expected to follow.

Recruitment Policy

We operate a robust recruitment policy, including conducting eligibility to work checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. This policy ensures that we only work with reputable employment agencies and conduct appropriate due diligence on any new agency we engage with.

4. Due Diligence Processes

ClarLabs has established due diligence processes to identify, assess, and mitigate the risk of modern slavery and human trafficking in our operations and supply chains. These processes include:

Supplier Due Diligence

Before engaging with new suppliers, we:

• Require completion of a supplier questionnaire that includes specific questions about labor practices and modern slavery prevention
• Conduct risk assessments based on geography, industry, and the nature of goods or services provided
• Validate the supplier's own modern slavery statements and policies where applicable
• Review public information and third-party reports for any evidence of modern slavery concerns
• Incorporate modern slavery clauses into our supplier contracts

Ongoing Monitoring

For existing suppliers, we:

• Conduct periodic reassessments based on risk levels
• Monitor media and public sources for concerns related to our suppliers
• Perform site visits for higher-risk suppliers where feasible
• Maintain open lines of communication with suppliers about modern slavery issues

Internal Due Diligence

Within our own operations, we:

• Conduct regular reviews of our recruitment and employment practices
• Ensure all staff have proper documentation and work permits where applicable
• Monitor working conditions and pay practices across all our locations
• Maintain robust grievance mechanisms accessible to all employees

Collaboration and External Resources

We enhance our due diligence by:

• Engaging with industry groups focused on ethical supply chains
• Utilizing third-party screening and monitoring services
• Staying informed about emerging best practices and guidance from governmental and non-governmental organizations

5. Risk Assessment and Management

Risk Assessment Process

Our approach to risk assessment involves a systematic analysis of our business operations and supply chains to identify potential modern slavery risks. We consider multiple risk factors, including:

• Geographical risks: Operations or suppliers in countries with weak labor protections or high prevalence of modern slavery
• Sector risks: Industries known to have higher prevalence of labor violations
• Transaction risks: Business models or spending patterns that could incentivize labor exploitation
• Business partnership risks: Relationships with entities that may have inadequate due diligence processes

Current Risk Profile

Based on our most recent risk assessment, we have identified the following areas as presenting a higher potential risk for modern slavery issues:

• Technology hardware suppliers with manufacturing processes in regions with lower labor standards
• Facilities management services, particularly cleaning and maintenance services
• Marketing merchandise and promotional materials supplied through extended global supply chains

Risk Mitigation Strategies

To address the identified risks, we have implemented the following mitigation strategies:

• Enhanced due diligence requirements for suppliers in high-risk categories
• Development of specific contractual safeguards for higher-risk supply relationships
• Preference for suppliers with strong demonstrated commitments to ethical labor practices
• Engagement with suppliers to improve transparency through their own supply chains
• Targeted audits and assessments for higher-risk suppliers

Continuous Risk Management

We maintain an ongoing risk management process that includes:

• Regular review and updating of our risk assessments
• Monitoring of external developments that may affect risk profiles
• Integration of modern slavery risk considerations into broader business decision-making
• Clear escalation paths for identified issues or concerns

6. Effectiveness in Preventing Modern Slavery

We understand the importance of measuring the effectiveness of our efforts to prevent modern slavery. To assess our progress and impact, we have established the following key performance indicators (KPIs) and review mechanisms:

Key Performance Indicators

• Percentage of staff who have completed modern slavery awareness training (target: 100%)
• Percentage of suppliers who have acknowledged our Supplier Code of Conduct (target: 100% of new suppliers, 90% of existing suppliers)
• Number of supplier due diligence assessments completed (target: 100% of new high-risk suppliers, 25% of existing supplier base annually)
• Response time to address reported concerns or incidents related to modern slavery (target: initial response within 24 hours, investigation initiated within 72 hours)
• Completion rate of planned supplier audits or assessments (target: 90% completion of planned assessments)

Review Mechanisms

To ensure ongoing effectiveness of our approach, we have implemented the following review mechanisms:

• Quarterly review of modern slavery KPIs by our Ethics Committee
• Annual review of policies and procedures relating to modern slavery
• Regular internal audits of our modern slavery controls and processes
• Engagement with external specialists to benchmark our approach against industry best practices
• Feedback mechanisms to gather insights from employees and suppliers on the effectiveness of our approach

Reporting and Transparency

We are committed to transparency regarding our efforts to address modern slavery risks. We:

• Document and report internally on all concerns raised and actions taken
• Include modern slavery prevention metrics in our annual Environmental, Social, and Governance (ESG) reporting
• Publish this Modern Slavery Statement annually, updating it to reflect our progress and emerging challenges
• Share learnings and best practices with industry peers and stakeholders

Current Performance

In the past financial year:

• 95% of staff completed modern slavery awareness training
• 87% of suppliers have acknowledged our Supplier Code of Conduct
• Due diligence assessments were completed for 100% of new suppliers and 23% of our existing supplier base
• No incidents or concerns related to modern slavery were reported
• 85% of planned supplier assessments were completed

7. Training on Modern Slavery

We are committed to building and maintaining awareness of modern slavery risks among our staff and key stakeholders. Our training program includes:

Employee Training

All employees are required to complete training on modern slavery awareness and prevention as part of our commitment to ethical business practices. Our training program includes:

• Onboarding training: All new employees receive information about modern slavery as part of their induction, including our policies and reporting procedures
• Annual refresher training: All employees complete an annual modern slavery awareness module, updated to reflect current risks and best practices
• Role-specific training: Enhanced training for employees in roles with higher exposure to modern slavery risks, such as procurement, HR, and senior management

Training Content

Our training covers:

• Definition and forms of modern slavery
• Legal and regulatory framework, including the UK Modern Slavery Act
• Risk factors and warning signs that may indicate modern slavery
• ClarLabs' policies and commitments regarding modern slavery
• Procedures for reporting concerns
• Case studies and practical examples relevant to our industry

Specialized Training

In addition to general awareness training, we provide specialized training for specific groups:

• Procurement team: In-depth training on supplier risk assessment, due diligence procedures, and ethical procurement practices
• Management team: Training on leadership responsibilities, risk management, and handling reported concerns
• Supplier-facing staff: Guidance on engaging with suppliers about modern slavery issues and monitoring compliance

Training Effectiveness

We evaluate the effectiveness of our training through:

• Pre and post-training assessments to measure knowledge improvement
• Feedback surveys to gather participant insights
• Tracking of reporting and inquiries related to modern slavery following training sessions
• Regular review and updating of training materials based on emerging risks and feedback

8. Goals and Future Steps

While we have made progress in our efforts to combat modern slavery, we recognize that this is an ongoing journey that requires continuous improvement. Our goals and planned actions for the coming year include:

Short-term Goals (Next 12 Months)

• Achieve 100% completion rate for modern slavery training across all staff
• Increase the percentage of suppliers acknowledging our Supplier Code of Conduct to 95%
• Enhance our supplier risk assessment methodology to incorporate more granular risk factors
• Develop and implement supplier self-assessment questionnaires for all medium and high-risk suppliers
• Establish a formal supplier audit program focusing on higher-risk categories
• Create more detailed guidance for staff on identifying and reporting modern slavery concerns

Medium-term Goals (2-3 Years)

• Implement a technology solution to better track, monitor, and report on supplier compliance with our modern slavery requirements
• Extend our modern slavery due diligence beyond tier 1 suppliers to include key tier 2 suppliers in high-risk categories
• Develop deeper relationships with expert organizations to enhance our approach to modern slavery prevention
• Create a supplier development program to assist smaller suppliers in improving their modern slavery prevention measures
• Explore opportunities for industry collaboration to address common modern slavery risks

Continuous Improvement Initiatives

To support our goals, we will undertake the following continuous improvement initiatives:

• Regular review and enhancement of our policies and procedures related to modern slavery
• Ongoing benchmarking against industry best practices and peer organizations
• Engagement with relevant stakeholders, including employees, suppliers, customers, and expert organizations
• Monitoring of evolving legal requirements and expectations related to modern slavery
• Incorporation of lessons learned from our own experiences and those of others in our industry

Performance Monitoring

We are committed to transparently monitoring and reporting on our progress toward these goals through:

• Regular updates to our Ethics Committee and Board of Directors
• Inclusion of modern slavery prevention metrics in our internal performance dashboards
• Public reporting through our annual Modern Slavery Statement
• Stakeholder communications on significant developments or achievements

9. Approval

This Modern Slavery Statement was approved by the Board of Directors of ClarLabs Ltd on March 15, 2025.

Signed,

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes ClarLabs' slavery and human trafficking statement for the financial year ending March 31, 2025.