Slavery and Human Trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain.
The policy of Taxback International and CluneTech is to conduct all of our business in an honest and ethical manner, and to comply with all applicable legislation. We strive to ensure that neither modern slavery nor human trafficking supports our supply chain or our businesses; this objective is implicit in our policies and procedures. We have a zero-tolerance approach to violations of anti-slavery and human trafficking laws. If breaches of these laws are found within our supply chain, we will support organisations as necessary to ensure compliance with the applicable legislation.
CluneTech has zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with these values.
We expect our suppliers to have suitable anti-slavery and human trafficking policies and processes in place.
CluneTech is committed to acting professionally and with integrity in all its business dealings and relationships globally. In order to identify and mitigate risk, we conduct regular audits of our supply chain.
The management team are responsible for compliance within their respective departments and in their supplier relationships.
All employees receive an induction into the business where our policies, procedures and expectations are outlined. Our training and practices are reviewed regularly to ensure those working with suppliers are aware of our requirements.
All employees and directors within CluneTech have a statutory obligation to report knowledge or suspicion of slavery or human trafficking. Any suspicion or knowledge of slavery or human trafficking is to be reported immediately to the Head of Compliance to determine what action, if any, is required . If the issue reported also relates to knowledge or suspicion of money laundering or terrorist financing then a further report is to be submitted to the Money Laundering Reporting Officer (MLRO).
Directors and employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal. These provisions do not replace any legal reporting or disclosure requirements. Where statutory reporting requirements and procedures exist, these must be fully complied with.
Concerns can also be outlined externally to the Modern Slavery Helpline.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement.