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The Clipper Group is a leading provider of value-added logistics solutions, e-fulfilment and returns management services. The Clipper Group continues to focus on developing innovative, cost-effective solutions that address the needs of our customers. Clipper 玩嘉电竞 plc is the parent company of the Clipper Group, which is made up of the following companies:

*The Modern Slavery Statement does not cover these entities.

The Clipper Group has a combined annual turnover of £696 million.

Our Business

Our business is managed through two distinct operating segments value-added logistics services (comprising e-fulfilment & returns management services and non-e-fulfilment logistics); and commercial vehicles. The first segment includes the receipt, warehousing, value-added processing, stock management, picking, packing and despatch of products on behalf of customers to support their online trading activities (e-fulfilment) or on behalf of customers generally (non-e-fulfilment), as well as a variety of ancillary and traditional retail support services. The second segment operates commercial vehicle dealerships from five locations, together with three sub-dealerships. It sells new and used vehicles, provides servicing and repair facilities, and sells parts.

 

Modern Slavery

Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are committed to ensuring that there is no slavery or human trafficking in our supply chain or in any part of our business. Our Anti-slavery and Human Trafficking policy reflects our commitment to acting ethically and with integrity in all our business relationships and implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

You can see a copy of our Anti-slavery and Human Trafficking policy here .

 

Supply Chain

Our supply chain includes organisations within the e-commerce and retail sectors.  

What Are We Doing to Prevent Modern Slavery?  

We believe that, in conjunction with the rigorous policies implemented by our clients and suppliers, we can drive out any aspects of human trafficking and slavery from our supply chains. As part of our initiative to identify and mitigate risk, we have in place a number of systems to:  

1. assess potential risk areas in our supply chains;  
2. mitigate the risk of slavery and human trafficking occurring in our supply chains;
3. monitor potential risk areas in our supply chains; and
4. protect whistle blowers.  

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we also provide training to our staff, the content and level of which is being reviewed as part of our Learning Evolved Strategy, as committed to within last year’s next steps.  

We educate our employees regarding the types of factors that can indicate whether any worker (permanent or temporary) in the Clipper Group’s business is subject to undue influence in doing so, the Clipper Group actively encourages employees to report any suspicious activity to the Chief People Officer, acting in their capacity as Compliance Manager.  

In addition, the Clipper Group operates an anonymous and independent compliance hotline called “SeeHearSpeakUp” for employees, agency workers and/or contractors which allows them to raise any concerns they may have. The hotline is operated by an independent third party that, once they have interviewed the employee about the concern raised, reviews the matter and escalates the issue to the Chief People Officer or other nominated senior managers, as applicable. This encourages employees to highlight any concerns or potential evidence of modern slavery and ensures that all matters raised through this hotline are addressed at board level.  

We also undertake, now on an annual basis, an ethical audit of our own facilities and our employment partners’ facilities to ensure compliance with the Ethical Trading Initiative (ETI) base code requirements. The Clipper Group has a preferred supplier list of labour agency partners and the organisations on that list will not be engaged unless they demonstrate a commitment to the same standards and agree to undertake this audit and comply with non-conformance remediation plans within prescribed time periods. Internal quarterly reviews have been implemented to ensure that we are continually developing our rigour and seeking to improve the value of what we do.  

Supplier Adherence to Our Values  

Based on our further steps from last year, we completed an Organisational Process Assessment (OPA) in conjunction with Stronger2gether which provided the foundations for Action Planning to further enhance our approach to tackling the risk of Modern Slavery and Human Rights violations.  

One of the key recommendations due to be implemented in the first quarter of the 2022/23 financial year are Global Business Standards. This document explicitly details the obligations regarding modern slavery and human rights to our suppliers and our expectations of the level of importance we expect from the Clipper Group and our suppliers.  

We will not knowingly work with any organisation within our supply chain that is unable to demonstrate a corresponding commitment to modern slavery, human trafficking and human rights, irrespective of whether they are required to do so statutorily or otherwise. Where possible, we build long-standing relationships with our customers and major suppliers, making clear our expectations of business behaviour. All suppliers are notified of the Clipper’s Anti-Slavery and Human Trafficking policy and other associated policies and are expected to comply with them.  

Going forward, other suppliers will be expected to demonstrate commitment to the same audit standards determined by a process of risk assessment criteria implemented following the Stronger2gether OPA conducted in 2021.  

Clipper conducts rigorous checks to verify the identity of each colleague and their right to work in the UK. We audit our agency suppliers against legislative compliance, including compliance with the Modern Slavery Act 2015.  

Further Steps  

Following a review of the effectiveness of our approach to anti-slavery, human trafficking and human rights, we intend to take the following steps:  

1. We will fully implement our Global Business Standards across our Supplier base  
2. We will continue with our multi-year OPA Action plan to ensure continued focus and development of robust processes and procedures  
3. We will implement updated training for colleagues at all levels to ensure effective knowledge, understanding and behaviours, mandating training of all managers across our organisation on an increased frequency basis  
4. Working with our auditing partners, we will develop the rigour of the Ethical Auditing process through our supplier base in conjunction with our Risk Assessment procedures, to ensure that we are interrogating all relevant areas of our supply chain  

Board Declaration  

This statement has been approved by Clipper 玩嘉电竞 plc’s board, who will review and update it annually, and has been personally executed by Tony Mannix, Chief Executive Officer.