Modern Slavery Act

MODERN SLAVERY ACT 2015 AND TRANSPARENCY IN SUPPLY CHAINS ACT OF 2010

This statement is published on behalf of Clarkson PLC and its subsidiary companies (together "Clarksons") pursuant to section 54(1) of the Modern Slavery Act 2015. This statement constitutes the Clarksons' Modern Slavery and Human Trafficking Statement for the financial year ended 31st December 2016.

About Clarksons

We are the world's leading provider of integrated shipping services; we work with our clients to achieve their business objectives across all aspects of this complex and dynamic industry including shipbroking, financial services, port services and research. We operate from 46 offices worldwide. For details of all the countries in which we operate, please go to /offices/.

Our strategy is to offer 'best in class' integrated global services underpinned by our culture as a socially responsible business with ethical behaviour as a core value.

Modern Slavery and Human Trafficking

Clarksons recognises that slavery, servitude, forced labour and human trafficking ("Modern Slavery") is a global and growing issue. No sector or industry can be considered immune. We are committed to ensuring that there is no Modern Slavery of any kind within our operations or supply chains.

Clarksons' Code of Business Conduct and Ethics (the "Code") is a set of principles and guidelines which support ethical behaviour and decision making at Clarksons. All employees worldwide are expected to adhere to the terms of the Code and to engage with any third parties who work on behalf of Clarksons to ensure that they also co-operate with the Code.

If an employee has a concern about any activities in the Clarksons' business, the Code provides a mechanism by which they can notify management. It is expected that all notifications under this Code are investigated as a matter of priority in order to reach a prompt resolution.

Respecting Employees' Rights

Clarksons believe that respect of human rights is integral to being a responsible company.

Clarksons places value on difference and believes that diversity of people, skills and abilities is a strength that helps us to achieve our best. Any discrimination based on race, religion, nationality, gender, age, marital status, disability, sexual orientation or political affiliation is prohibited within the business.

We are committed to providing a workplace free of any form of harassment or discrimination and expect our suppliers to do the same.

Our Supply Chain

The supply chain to our business comprises of worldwide suppliers providing a wide range of support functions and products including catering, maintenance, information technology, cleaning and security.

Next steps

Clarksons are committed to building and strengthening our existing policies and practices to eliminate Modern Slavery and human rights violations within our supply chain.

Our next step is to review the effectiveness of the current arrangements and, where necessary, implement additional safeguards and procedures. This is expected to include:

  • Review of existing procurement procedures (e.g. supplier questionnaires) and other relevant internal policies and procedures and make recommendations for any appropriate changes.
  • Include specific requirements in our procurement vetting processes for prospective suppliers to disclose their position on human rights, modern slavery and human trafficking and require them to provide evidence of policies/procedures as appropriate.
  • Risk assessment of supply chains to identify areas which may at higher risk of Modern Slavery and/or human trafficking;
  • Appropriate training for our employees regarding the Modern Slavery Act requirements.

This statement has been approved by the board of Clarkson PLC on 3 February 2017.

 

Jeff Woyda

Chief Financial Officer and Chief Operating Officer

Clarkson PLC

Date: 3rd February 2017