Anti-Slavery and Human Trafficking Statement 2017


This statement is made on behalf of the UK companies, White Clarke Group Holdings Limited and WC Midco 2 Limited, hereafter referred to as “the Group” to address section 45 (1) of the Modern Slavery Act 2015. Registered office: 10 Queen Street Place, London, EC4R 1AG.

The company has a few subsidiaries including White Clarke Group Limited, WC Midco, WC Bidco, LS2 Limited, White Clarke Group India, Beijing White Clarke Group Software System co. Ltd, White Clarke North America Inc, White Clarke Group Inc, White Clarke Germany GmbH, E D White & Co. Ltd, Unwired Limited, WCAP Holding Pty Ltd, White Clarke (Ireland) Ltd, White Clarke Austria GmbH, White Clarke Asia Pacific Pty Ltd, Business Services Bureau Australia Pty Ltd (together, the “Group”)

The Group are 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 and is made pursuant to section 54(6) of the Act and constitutes the Company’s anti-slavery and human trafficking statement for the financial year ending on 31 December 2017. The Group aim 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 Group Holdings Limited is the holding company for White Clarke Group Limited (WCG) which operate as a world leading provider of end-to-end automotive, consumer and asset finance software for the retail, fleet and wholesale business. Delivering proven, innovative software solutions to more than 100 of the world's leading finance organizations in 30 countries. WCG employees more than 400 employees globally with an annual turnover of £62 million in the year ended 31st December 2017.

WCG operates in the UK, North America, Asia, Australia and Europe, with its head office of operations located in the UK.

WC Midco 2 Limited (WC2) is the holding company of White Clarke Group Holdings Limited and all its subsidiaries.

Supply chain management

As a software provider the Group does not have a supply chain (local or international) where modern slavery or human trafficking would be a risk, as a general rule contractors and suppliers used by the Group are therefore not likely to be susceptible to this risk. The Group 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

The Group’s policy to this effect is included in the Corporate social responsibility statement, the Anti-bribery and corruption policy and our equal opportunities policy.

Employees 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

The Group 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.
  • The Group plan to develop a specific modern slavery policy and include in all global handbooks.
  • The Group is establishing our Whistleblowing policy to encourage its employees to speak up and report any wrongdoing.

This will support existing policies setting out the Group’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:

  • The Group will continue to monitor and assess potential risks across the business and our supply chains.
  • Procurement and sales team will include risk assessments as part of their processes and will report any potential risks.
  • Implementation of our Whistleblowing policy & protection for whistle blowers.
  • Implementation of Modern Slavery policy in all global handbooks.

Recruitment & Selection

The Group follows a clearly defined recruitment and selection process ensuring that only reputable agencies are used to source employees.

All subsidiaries of the Group ensure appropriate controls are in place to ensure employees have the right to work and are therefore protected by relevant employment legislation, including but not limited to checking for right-to-work documents, visas and passports.

Effectiveness in combatting slavery and human trafficking

The Group understands that it has a responsibility to continue to assess and mitigate the risk of modern slavery. While the Group 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.
White Clarke Group aims to:

  • Extend the modern slavery training to all White Clarke Group employees
  • Monitor other large companies’ perspectives and approaches to modern slavery and ensure the Group are in line with these approaches where applicable to our business.

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 2017.

Signed by Perry Scanlon, Group Chief Financial Officer
Board approval date: 28/03/2019
UK modern slavery act compliance and anti-slavery statement central register