Anti-Slavery & Human Trafficking Statement 2024/25

This statement is made pursuant to section 54(6) of the Modern Slavery Act 2015 and relates to the activities for the financial year ending 31st October 2025 of Clear Group (Holdings) Limited and all of its subsidiary companies, together referred to in this statement as “Clear”. 

 

Published March 2025.

 

Anti-Slavery & Human Trafficking Statement 2024/25

Clear is an UK based insurance broker. We are committed to ensuring that modern slavery and human trafficking have no place in our business or supply chains. As a responsible insurance broker that is regulated by the FCA, we take our responsibilities to our people, our supply chains, and our clients seriously and we will continue to act ethically and with integrity in all of our business dealings.

Clear has a zero-tolerance policy to slavery and human trafficking in all its forms. We are dedicated to implementing, maintaining and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our business or supply chains, and we expect the same high standards from all our contractors, suppliers, and other business partners.

We believe that working practices in the insurance broking sector are not deemed to be a key risk area in terms of slavery and/or human trafficking as our employees work primarily in office-based roles across the UK and the European locations in which we operate. Our suppliers are largely UK based and also within low-risk sectors.

We have policies and procedures in place where relevant and required that are designed to identify potential risks in our business, and to reduce the risk of slavery and human trafficking occurring in our business and supply chains.  As part of our commitment to combating slavery and human trafficking, we:

  • Have formulated an Anti-Slavery Policy that identifies and seeks to mitigate and monitor the risk of modern slavery within our business and supply chain, and which encourages the reporting of any concerns;
  • Will evaluate the risk of any slavery and human trafficking within any new supplier and continue to keep existing relationships under review;
  • Implement robust recruitment processes to ensure all employees have the legal right to work in the UK (or relevant jurisdiction in which we operate), and ensure that we have fair recruitment policies and procedures;
  • Engage our staff on full-time, part-time or fixed term basis with flexible working arrangements as may be agreed from time to time, and ensure all staff are fairly remunerated and incentivised for the work which they undertake for Clear;
  • Will continue to ensure all our staff have written employment contracts and are aware of their statutory rights, and have in place appropriate policies for the management of all employees which allow for a safe working environment;
  • Shall implement training for all staff, as well as additional guidance to staff members involved in managing recruitment and our supply chains;
  • Will encourage employees to identify and report any concerns or potential breaches regarding modern slavery and human trafficking within the business and our supply chains. Reports can be made confidentially through our whistleblowing policy or through our Speak Up reporting line;
  • Will work with our current and future suppliers to ensure their commitment to the same high standards.
Mike Edgeley 1

From our CEO

We are committed to continuously reviewing and improving our policies and practices to combat modern slavery and human trafficking. This statement will be reviewed annually and updated as necessary.

This statement has been approved by the Board of Directors of Clear Group (Holdings) Limited.

 

Mike Edgeley

Group CEO

The Clear Group