Modern Slavery and Human Trafficking Policy
1. Policy Statement
CRKLR.com is committed to preventing modern slavery and human trafficking in all its forms within our business operations and supply chains. We recognize that modern slavery is a serious crime and a violation of fundamental human rights that affects millions of people worldwide.
This policy demonstrates our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our business or supply chains.
2. About Our Organization
Company: CRKLR Limited (14199299)
Industry: Marketing and Advertising Agencies
Policy Effective Date: 01.07.2022
Policy Review Date: 01.04.2026
3. Organizational Structure and Supply Chains
CRKLR.com operates as [insert brief description of business model and primary activities]. Our supply chains include:
- Technology service providers and hosting platforms
- Software and digital tool vendors
- Marketing and advertising partners
- Professional services (legal, accounting, consulting)
- Office suppliers and facility management
- [Additional relevant suppliers specific to business operations]
4. Our Policies on Slavery and Human Trafficking
We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our approach includes:
4.1 Zero Tolerance Approach
- We have zero tolerance for slavery and human trafficking
- We expect all those in our supply chain to comply with our values and standards
- We will not knowingly work with any organization involved in slavery or human trafficking
4.2 Employee Rights and Working Conditions
- All employees have the right to fair wages, reasonable working hours, and safe working conditions
- We prohibit the use of forced, compulsory, or trafficked labor
- We ensure all employees have the right to leave their employment and have their movement unrestricted
- We provide clear contracts and terms of employment
4.3 Recruitment Practices
- We use only specified, reputable employment agencies and verify their practices
- We ensure all employees have the legal right to work in their location
- We do not charge recruitment fees to workers
- We require all identity documents to be freely accessible to their holders
5. Due Diligence Processes
5.1 Supplier Due Diligence
We undertake due diligence when considering taking on new suppliers, including:
- Evaluation of modern slavery and human trafficking risks
- Review of supplier policies and procedures
- Assessment of supplier compliance with relevant laws and regulations
- Regular monitoring of supplier performance
5.2 Risk Assessment
We regularly assess the risk of modern slavery and human trafficking in our operations and supply chains by:
- Mapping our supply chains to identify high-risk areas
- Conducting regular risk assessments of existing suppliers
- Monitoring changes in supplier operations and locations
- Staying informed about modern slavery risks in relevant industries and regions
6. High-Risk Areas
We recognize that certain areas of our business may present higher risks for modern slavery and human trafficking:
- International suppliers and subcontractors
- Labor-intensive operations
- Suppliers in high-risk geographical locations
- Recruitment and employment practices
- Subcontracting arrangements
7. Training and Awareness
7.1 Staff Training
- All staff receive awareness training on modern slavery and human trafficking
- Procurement and management teams receive enhanced training
- Training is updated regularly to reflect current risks and legislation
7.2 Supplier Engagement
- We communicate our expectations to suppliers regarding modern slavery
- We provide guidance and support to help suppliers meet our standards
- We encourage suppliers to implement their own modern slavery policies
8. Reporting and Whistleblowing
8.1 Reporting Mechanisms
We encourage anyone who has concerns about modern slavery to report them through:
- Direct reporting to management
- Anonymous reporting mechanisms
- Third-party reporting services where available
8.2 Protection for Reporters
- We provide protection for individuals who report concerns in good faith
- We investigate all reports thoroughly and confidentially
- We take appropriate action based on investigation findings
9. Measuring Effectiveness
We measure the effectiveness of our approach through:
- Regular review and updating of risk assessments
- Monitoring of supplier compliance
- Analysis of training completion rates and feedback
- Review of reported concerns and actions taken
- Annual assessment of policy effectiveness
10. Supplier Requirements
All suppliers must:
- Comply with all applicable laws relating to modern slavery and human trafficking
- Implement appropriate policies and procedures to prevent modern slavery
- Conduct their own due diligence on their supply chains
- Report any concerns or incidents immediately
- Cooperate with any investigations or audits
- Provide evidence of compliance when requested
11. Non-Compliance and Remediation
If we identify non-compliance with this policy:
- We will work with suppliers to develop corrective action plans
- We will provide reasonable time frames for remediation
- We may terminate relationships with suppliers who fail to meet our standards
- We will report serious violations to appropriate authorities
12. Continuous Improvement
We are committed to continuous improvement in our approach to preventing modern slavery through:
- Regular policy reviews and updates
- Stakeholder engagement and feedback
- Industry collaboration and best practice sharing
- Investment in new technologies and processes
- Monitoring of legislative and regulatory developments
13. Governance and Oversight
13.1 Board Oversight
This policy has been approved by the board and is reviewed annually.
13.2 Responsibility
Overall responsibility for this policy lies with Justin Thomas, Director with day-to-day including day to day management.
14. Annual Statement
This policy supports our annual Modern Slavery Statement, which is published on our website in accordance with Section 54 of the Modern Slavery Act 2015 (where applicable).
15. Contact Information
For questions about this policy or to report concerns:
Email: justin@crklr.com]
Address: First Floor, 192-194 Vauxhall Bridge Road, London, SW1V 1DX
Policy Owner: Justin Thomas
Approved By: Justin Thomas
Date of Approval: 01.04.2025
Next Review Date: 01.04.2026
Version: 1.1
This policy will be reviewed annually and updated as necessary to ensure it remains current and effective.