Modern Slavery Statement
Overview
In line with the requirements of the Modern Slavery Act 2015 (“the Act”) and in accordance with section 54 of the Act this statement outlines the steps that Candid Insurance Services Limited trading through the Clark UK, Tom and Polly brands (‘Clark UK’ or ‘It’) has taken in the financial year ending 31 December 2024 to prevent, and to address, any form of modern slavery within its business operations and/or supply chain.
Clark UK is a member of Clark Group (“Clark”), which has its head office in Germany and operates in Germany, UK, France, Netherlands and Switzerland. Clark Group carries on business within the UK through its subsidiary Clark UK.
Clark UK is an insurance broker, providing access to insurance protection services such as life insurance, income protection and private medical insurance through its own digital platforms including mobile apps and websites.
Clark UK recognises that modern slavery is a violation of fundamental human rights and freedoms. It is fully committed to respecting human rights, and will take measures to eradicate, address and mitigate any risk or instance of modern slavery that might arise within its operations and/or supply chain.
It is a priority for the organisation to ensure that it trades ethically, sources responsibly and takes action to prevent modern slavery and human trafficking.
This statement highlights the key activities undertaken during the last financial year to combat modern slavery in the organisation and/or its supply chain.
Speak Up Policy
The CLARK Group Speak Up Policy was introduced on 1st July 2023 and last updated on 6th August 2024 with a 12 month revision cycle.
Speak Up is Clark’s whistleblowing policy that sets standards within the organisation for raising concerns about misconduct. It covers all employees in all subsidiaries and locations within the Group.
Non-compliance with laws, regulations, internal standards and policies, if occurs, can become a serious obstacle on the way to Clark’s goal of becoming the fastest growing and most efficient insurance broker in Europe.
Clark has introduced the Speak Up policy to clearly define what kind of
violations can be reported, what channels can be used for reporting and confirming that the reporting person will be protected from retaliation.
Employees can use the available internal and external channels to report violations of the laws or breaches of the CLARK Group Code of Conduct and other internal policies and procedures including issues relating to breach of modern slavery and human trafficking.
IntegrityLine is Clark’s internal reporting system. It can also be used for anonymous reporting. Issues can also be reported to the Compliance team or to individual Compliance managers, HR managers, or line managers. Employees are free to choose who they feel most comfortable raising issues with. The platform is available not only to internal employees but also to external stakeholders for the reporting of any compliance concerns.
Clark guarantees that all reports will be handled with the utmost confidentiality.
The Speak Up policy is approved by Clark’s CLARK Group Executive Committee and is reviewed annually.
Code of Conduct
“We all work hard to achieve the best reputation and win the trust of our customers. We encourage you to lead by example and to speak up if you see any violations of our Code of Conduct.”
Joshua Sargent, CEO Clark UK
Clark’s Code of Conduct sets out standards for compliant and ethical behavior within the group. It serves as a compass and gives orientation in our everyday actions and decisions.
Compliance means adhering to all legal and regulatory obligations as well as our own policies and standards. Integrity at Clark is about acting
honestly and holding up to our ethical values.
Clark Group Code of Conduct is approved and issued by the Executive
Committee and applies to everyone at Clark at all locations and company
levels.
Supply Chains
Clark UK’s supply chains primarily include: suppliers of software and technology solutions, providers of office equipment and services, professional service providers and employee benefit providers.
Diligence in dealing with our business partners ensures that everything that is done for our customers is done in an orderly and proper way.
A risk-based business partner due diligence process is implemented and includes screening for compliance risks and adverse media.
We treat our business partners fairly and expect them to hold to the same high compliance and ethical standards that we set to ourselves.
We recognise the importance of identifying high-risk areas where our activities might be causing or contributing to adverse human rights
impacts, including modern slavery. Insurance has not been identified as a high-risk sector, where direct employees might experience modern slavery or forced labour. Our direct operations rely on knowledge and skills based activities where almost all our employees work in roles that are low risk, for example in office-based roles, including sales advisor roles and other roles that require specialist experience and/or qualifications such as compliance, accountancy, software development, marketing and human resources.
We have a limited degree of exposure to the risks of forced labour practices in our supply chain, especially where we source services produced by manual labour, such as outsourced cleaning services.
The business operations are Europe-based and oriented to the European customers without reliance on complex global supply chains.
Underwriter
Clark UK’s life insurance and serious Illness cover policies are underwritten by iptiQ, a division of the Swiss Re Group. Swiss Re has a long-standing commitment to corporate responsibility. Swiss Re complies with the UN Guiding Principles on Business and Human Rights and is a signatory to the UN Global Compact. Swiss Re are also signatories to the UN-supported Principles for Responsible Investment and to the United Nations Principles for Sustainable Insurance.
Compliance
If we find evidence of a failure to comply with our standards in respect of Modern Slavery or a breach of legislation in this area we will immediately seek to terminate our relationship with the relevant supplier. Where there are suspicions of a breach, we will take positive action to investigate and either terminate where proven, or work with the supplier to demonstrate with greater certainty that there is no such breach.
Organisations within our supply chains are required to adhere to the Modern Slavery Act as a contractual requirement.
Inclusion, Respect and Diversity
We share a common vision and a mutual goal – our differences and diversity help us to achieve it. We value all members of our community for their unique contributions to delivering the best experience for our customers.
We foster open, inclusive and respectful culture in our everyday work, in our hiring and promotion practices and in our communication. Nobody at Clark or its environment has to experience exclusion or discrimination regardless of gender, age, religion, cultural background, sexual orientation, disability or other diverse backgrounds.
Instead, we always seek to learn from different perspectives and thus truly
understand and meet the diverse needs of our customers and our community.
We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We regularly review and update our Code of Conduct and Speak Up policies as set out above.
Our Employees
In the UK, we manage the risk of modern slavery by ensuring that the people we hire have the right to work and that their basic rights as workers are protected.
We comply with UK employment laws including the Working Time Regulations.
We have reviewed our third-party recruitment agencies’ practices. Within this review, we have confirmed their low-risk status and that they comply with an “employer pays” principle, ensuring no recruitment fees are charged to potential candidates and all terms and conditions are disclosed at the recruitment stage.
UK Whistleblowing Policy
In addition to the Group Speak Up policy and Code of Conduct detailed above, there is a specific UK Whistleblowing policy which was last updated in March 2025 and has a 12 month revision cycle.
High Level Approval
Clark’s CLARK Group Executive Committee have assessed this statement and have approved its content on 18 July 2025.