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 second 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 2018. This statement sets out the steps taken during the financial year ended 31 December 2018 by the Company to prevent modern slavery and human trafficking in its business and supply chains.
During 2018 the group has focused efforts on reviewing its whistleblowing policy and procedures and training of appropriate teams on supply chain management.
The Company’s modern slavery statement 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 2018. The Group 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 Group Holdings Limited is the holding company for White Clarke Group Limited 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. White Clarke Group employs more than 400 employees globally with an annual turnover of £62 million in the year ended 31st December 2018.
White Clarke Group 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.
We have undertaken a review of the anti-slavery internal controls during the year ended 31 December 2018, with the purpose of:
- Identifying, assessing and monitoring potential risk areas in the supply chains; and
- Mitigating the risk of slavery and human trafficking occurring in the supply chains.
This review has not led to revisions of the existing internal controls.
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.
The Group understands that it has a responsibility to continue to assess and mitigate the risk of modern slavery across the business in the long term.
We have undertaken a review of the anti-slavery policies during the year ended 31 December 2018, with the purpose of:
- Identifying, assessing and monitoring potential risk areas
- Enhancing the training of our procurement teams
- Protect whistle-blowers
The Group have provided either training or training updates on the modern slavery regulation to the relevant personnel or departments within the company who are directly involved in procurement or who have governance of procurement.
The Group have included their modern slavery policy in the Global Code of Conduct and made available to all employees globally.
The Group are in the process of implementing a fully robust Whistleblowing process.
Identified risks and steps taken to prevent and manage the risks
To assess the effectiveness of controls to ensure modern slavery does not exist within any of the Group’s business activities, the Group aims to, in 2018/2019:
- Reassess any modern slavery risks identified in light of any changes to the way the Group does business and put in place corrective actions in response to these risks in its business or supply chain as appropriate;
- Extend the modern slavery training to all relevant professionals;
- The Group will launch a robust Whistleblowing process to encourage its employees to speak up and report any wrongdoing
- Monitor government and other large companies’ perspectives on and approaches to modern slavery and actively consider their applicability to the Group.
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.
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 employees
- Updates to our internal training platform to broaden knowledge of this critical area amongst all global employees
Signed by Robert Scanlon on behalf of White Clarke Group Holdings Limited and WC Midco 2 Limited.
Board approval date: 02/02/2020