Blog

Modern Slavery Policy

This policy was last reviewed and updated: 12 March 2026

Clarus Digital Ltd (“we”, “us”, or “our”) is a UK-registered digital marketing and creative agency operating from offices in London (Shoreditch) and Brighton. This policy sets out our commitment to combating modern slavery and human trafficking in all forms, and the steps we take to ensure neither exists in our business or in the supply chains we rely upon.

While Clarus Digital Ltd falls below the £36 million annual turnover threshold that makes publication of a modern slavery statement a legal requirement under Section 54 of the Modern Slavery Act 2015, we publish this policy voluntarily. We do so because we believe transparency and ethical business conduct are non-negotiable, and because we align our practices with the Home Office’s updated Transparency in Supply Chains (TISC) Statutory Guidance, published in March 2025.

Our business and supply chains

Clarus Digital Ltd provides digital marketing services including SEO, paid advertising, social media management, content marketing, web design and development, and creative services. Our clients are predominantly UK-based businesses. Our workforce is small, UK-based, and directly employed or engaged on a freelance basis.

Our supply chain is low-risk by nature. It consists primarily of:

  • Software, platform, and SaaS providers (e.g. analytics, project management, design tools)
  • UK-based freelance specialists (copywriters, developers, designers)
  • Digital advertising platforms (Google, Meta, and similar)
  • Professional services providers (accountancy, legal)

We do not manufacture goods, operate internationally, or engage with supply chains that carry elevated modern slavery risk. However, we recognise that no business is entirely without risk, and we take our responsibilities seriously.

Our commitment

Clarus Digital Ltd has a zero-tolerance approach to modern slavery, human trafficking, forced labour, and unlawful child labour — whether within our own operations or in those of our suppliers, subcontractors, and business partners.

We are committed to:

  • Acting ethically and with integrity in all our business dealings
  • Ensuring our recruitment and employment practices are fair, transparent, and compliant with UK employment law
  • Implementing and enforcing effective systems to identify and respond to any modern slavery risk
  • Encouraging openness and ensuring that concerns can be raised safely and without fear of retaliation

Definitions

Modern slavery is an umbrella term covering a range of serious criminal offences under the Modern Slavery Act 2015, including:

  • Slavery and servitude — owning or treating a person as property and forcing them to work
  • Forced or compulsory labour — work extracted under threat of penalty that a person has not voluntarily offered to perform
  • Human trafficking — the recruitment, transportation, or receipt of persons through force, fraud, or coercion for the purpose of exploitation
  • Harmful child labour — the employment of children in ways that are economically exploitative, hazardous, or harmful to their health, education, or development

Our policies

We maintain the following internal policies and practices that support our commitment to preventing modern slavery:

  • Recruitment policy — we verify the right to work for all employees and contractors in the UK and do not use recruitment channels associated with exploitation
  • Whistleblowing policy — we operate an open-door policy and encourage anyone with concerns about modern slavery or labour exploitation to raise them confidentially without fear of reprisal
  • Supplier and contractor code of conduct — all suppliers and freelancers we engage with are expected to comply with applicable employment law and share our values on ethical working practices
  • Fair pay commitment — we pay at least the National Living Wage to all workers and do not make unlawful deductions from wages

Due diligence and risk assessment

Given the nature of our business and supply chain, our overall modern slavery risk is assessed as low. Our due diligence measures include:

  • Reviewing new suppliers and freelancers before engagement, including checking business credentials and registration where appropriate
  • Preferring UK-based or well-established international suppliers with their own stated ethical standards
  • Including anti-slavery and ethical conduct expectations in our supplier and freelancer agreements
  • Remaining alert to indicators of forced labour or exploitation in any business relationship

We will review and update our risk assessment annually or whenever there is a material change to our business or supply chain.

Training and awareness

We ensure that relevant members of our team are aware of modern slavery, how to recognise potential indicators, and how to report concerns. This includes:

  • Briefing new staff and contractors on this policy as part of onboarding
  • Ensuring leadership is familiar with the Modern Slavery Act 2015 and the Home Office’s updated TISC Statutory Guidance (March 2025)
  • Reviewing our training approach annually as guidance and best practice evolves

Reporting concerns

Anyone who has concerns about potential modern slavery, human trafficking, or forced labour — whether within Clarus Digital Ltd or among our suppliers — is encouraged to report this immediately. Reports can be made:

  • Internally: by contacting a director of Clarus Digital Ltd directly
  • By email: [email protected]
  • Externally: via the Modern Slavery Helpline on 0800 0121 700 (free, 24/7)

Concerns can also be reported to the Gangmasters and Labour Abuse Authority (GLAA): gla.gov.uk, or to the National Crime Agency (NCA): nationalcrimeagency.gov.uk.

Consequences of non-compliance

Clarus Digital Ltd takes any breach of this policy extremely seriously. If a supplier, subcontractor, or business partner is found to be engaged in modern slavery or refuses to cooperate with any compliance verification:

  • We will terminate any supply agreement, arrangement, or contract with that party immediately and without compensation
  • We will take such remedial steps as are necessary to address the breach and prevent recurrence
  • We will report the matter to the relevant authorities where appropriate

Review and continuous improvement

This policy will be reviewed annually and updated to reflect changes in our business, supply chains, and the evolving legislative and guidance landscape. We are committed to making year-on-year progress in addressing modern slavery risk, in line with the Home Office’s updated Transparency in Supply Chains guidance and the principles of the UN Guiding Principles on Business and Human Rights.

For further information about the Modern Slavery Act 2015 and the UK Government’s guidance, visit: gov.uk/government/collections/modern-slavery.

Contact

For any questions about this policy, please contact us:

  • Email: [email protected]
  • Phone: 01273 042470
  • Post: Clarus Digital Ltd, 3rd Floor, 86–90 Paul Street, London, EC2A 4NE

This policy has been approved by the directors of Clarus Digital Ltd and reflects our commitment to ethical business conduct.

Clarus Digital Ltd — Company Reg. 15417042 — clarusdigital.co.uk

This policy was prepared on 12 March 2026.