Clarkes Modern Slavery Statement


This statement sets out Clarkes of Walsham’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 January 2022 to 31 December 2022.

As part of the retail sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
Clarkes of Walsham is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Clarkes

Clarkes are one of the largest independent suppliers of Building, Farming and Garden Materials in East Anglia, and fast becoming the number one outlet for Cartridge and Shooting Accessories in East Anglia and beyond.

We fully support international efforts to promote ethical principles and practices related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking. We also expect commitment to these principles from all organisations with which we do business and will not support or do business with others who are knowingly involved in slavery or human trafficking.

Responsibility for our anti-slavery initiatives is as follows:

  • Anti-slavery policy. This sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
  • Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or about practices within our business or supply chain, without fear of reprisals.
  • Neil Elers, Purchasing Director is responsible for identification, investigations, and due diligences process that we carry out to ensure that there is no slavery or human trafficking in our business and supply chains.
  • Training is provided to our buyers to ensure they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
  • Employee code of conduct, our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier code of conduct - We are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship. We conduct due diligence on all suppliers before allowing then to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
  • Recruitment - We do not use employment agencies to source labour, all recruitment is undertaken in-house and includes eligibility to work in the UK checks for employees to safeguard against human trafficking or individuals being forced to work against their will.

Performance indicators

We will know the effectiveness of the steps we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

We will be requiring all supply chain managers/HR professionals to have completed training on modern slavery by 1st August 2022.

Awareness-raising programme

We have raised awareness of modern slavery issues by distributing flyers to staff common rooms, briefing of what modern slavery is and how to identify the signs and putting up posters

The briefing and posters explain to staff:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
• what external help is available, for example through the Modern Slavery Helpline (0800 0121 700).
This statement was approved by the board on Wednesday, 29th June 2022.

This statement was approved by the Board of Director,

Name: Neil Elers
Position: Purchasing Director

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