Cleared London Modern Slavery Statement

Cleared London is committed to publishing a clear and robust Modern Slavery Statement that reflects our corporate values and our duty to eradicate modern slavery and human trafficking from our operations and supply chains. This statement sets out our approach, including a zero-tolerance policy, supplier engagement and audit procedures, secure reporting channels, and an annual review process to measure and improve our performance.

Our anti-slavery statement applies to all employees, contractors and partners associated with Cleared London. We pursue a zero-tolerance policy towards forced labour, servitude, bonded labour, involuntary prison labour, human trafficking and any form of exploitative labour practice. Any breach of this policy will result in swift disciplinary action and remediation measures, including termination of relationships with third parties where appropriate.

As part of our slavery and human trafficking statement, Cleared London requires all suppliers to comply with our standards and contractual clauses. We expect suppliers to implement appropriate due diligence, maintain accurate employment records, and ensure safe working conditions. We will not knowingly engage with suppliers who exploit workers or circumvent labour protections.

Supplier Audits and Due Diligence

To assure compliance we conduct a proportionate risk-based due diligence programme. This includes pre-engagement screening, ongoing monitoring and periodic on-site and remote supplier audits. Typical elements of our supplier audit process include:

• Verification of identity and employment records;
• Review of payroll, working hours and recruitment practices;
• Interviews with workers and management where accessible;
• Assessment of subcontractor and labour provider arrangements;
• Remediation plans for any identified issues, with clear timeframes and follow-up.

Audit frequency is determined by risk factors such as geographic location, industry sector and the nature of the goods or services supplied. High-risk suppliers receive enhanced scrutiny, while strategic partners collaborate with Cleared London on improvement plans. We use a combination of internal audit teams and independent third-party assessors to ensure objectivity.

Reporting Channels and Protection for Reporters

Cleared London maintains multiple safe and confidential reporting channels to encourage the prompt disclosure of concerns. These channels are designed to protect whistleblowers from retaliation and to ensure that reports are investigated thoroughly and impartially. Our reporting mechanisms include:

• Anonymous reporting options through third-party hotlines and secure digital forms;
• Internal reporting to designated compliance officers and human resources;
• Formal investigation procedures with documented outcomes and corrective actions;
• Support measures for affected workers, including access to remediation and recovery services where applicable.

All reports are treated seriously and assessed according to a standardized triage process. Investigations are led by trained personnel and may involve external experts. Cleared London is committed to transparency in enforcement while maintaining confidentiality where necessary to protect individuals and the integrity of investigations.

Annual Review and Continuous Improvement: We review this Modern Slavery policy and our slavery and human trafficking statement at least once every 12 months. The annual review evaluates the effectiveness of our due diligence, audit outcomes, remediation activities and the adequacy of our reporting channels. Findings from each review inform updated risk assessments, training programmes, and supplier engagement strategies.

In addition to the formal annual review, Cleared London holds regular training and awareness sessions for employees and supply chain partners to reinforce obligations under our modern slavery statement. We also set measurable objectives and key performance indicators to drive progress and report on these measures internally to senior leadership and the board.

Cleared London recognises that eliminating modern slavery is an ongoing commitment requiring collaboration, vigilance and improvement across the whole value chain. Our anti-slavery statement represents both a legal and moral pledge to protect human rights and to ensure that labour standards are upheld. We will continue to strengthen controls, scale audits, refine reporting channels and update our policies as needed following each annual review.