Published 2026-08-26
1.0 Introduction
Modern slavery is a heinous crime and tackling it is a top priority of governments around the world and for C&R Software.
Businesses have a vital role to play. Modern slavery is a brutal way of maximizing profits, by producing goods and services at ever lower costs with scant regard for the terrible impact this has on individuals. Our message is clear: businesses must not be knowingly or unknowingly complicit in this horrendous and
sickening crime.
This policy explains how C&R Software complies with the United Kingdom Modern Slavery Act and other similar legislation worldwide. The United Kingdom Modern Slavery Act requires all large businesses to produce an annual statement setting out the steps they have taken to prevent modern slavery in their business and supply chains.
Of course, transparency statements on their own are not enough. The challenge for businesses is to take serious and effective steps to identify and root out contemporary slavery which can exist in any supply chain, in any industry. All businesses must be vigilant and aim to continuously improve.
2.0 C&R Software's Adopted Ethos
Organizations which do not meet the requirements in the Act can still choose to voluntarily produce a slavery and human trafficking statement. Smaller organizations may be asked by those they are supplying goods or services to whether they have a statement or policy setting out their approach to tackling modern slavery, especially if they are bidding for contracts with larger businesses above the threshold. Therefore, smaller organizations may find it helpful to voluntarily produce a statement as a means of managing these
requests and providing a level of assurance to their customers.
Even where legislation does not apply, C&R Software encourages all businesses to be open and transparent about their recruitment practices, policies, and procedures in relation to modern slavery, and to take steps that are consistent and proportionate with their sector, size, and operational reach.
This document contains a step-by-step look at anti-slavery and how C&R Software manages its policy to uphold and comply with the Modern Slavery Act 2015.
Furthermore, there is a requirement to complete training and, where applicable, pass an assessment to demonstrate a good understanding of the knowledge gained and retained on this subject.
C&R Software also recognizes applicable laws in the jurisdictions where we operate, including but not limited to:
- United Kingdom Modern Slavery Act 2015
- Australia's Modern Slavery Act 2018
- California Transparency in Supply Chains Act
- Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211)
We commit to aligning our programme with these and any successor laws.
As a fully remote organization operating across multiple jurisdictions with no physical offices or on-premises operations, C&R Software acknowledges that our supply chain and workforce risks differ from those of organizations with physical manufacturing or on-site labor-intensive operations. Nevertheless, we
are fully committed to identifying, preventing, and addressing modern slavery risks wherever they may exist including in our digital supply chains, technology vendors, and contractor relationships.
3.0 Policy Statement
Slavery is illegal and a violation of human rights. There are many forms of modern slavery, including:
- Forced labor
- Child labor
- Exploitation
- Being controlled by an employer
- Debt bondage
- Being physically constrained
- Being sold or treated as a commodity and having restrictions on freedom of movement
These acts involve a person losing their freedom by being exploited by another for personal or commercial gain.
C&R Software has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships. We will implement and enforce effective systems and controls to ensure modern slavery is not taking place in our own business or supply chains.
We are committed to ensuring our business is transparent and, as such, will comply with the disclosure obligations under the Modern Slavery Act 2015.
C&R Software expects our contractors, suppliers, and other business partners to uphold high standards in all business practices. As part of the contracting process, we include prohibitions against the use of staff sourced from forced, compulsory, or trafficked labor, or anyone held in slavery or servitude. C&R Software expects all suppliers to uphold these high standards.
C&R Software will engage with relevant suppliers to ensure compliance with the Modern Slavery Act 2015.
In addition, we will audit higher-risk suppliers as determined by our predetermined criteria.
This policy applies to all persons working for, or on behalf of, C&R Software in any capacity. This includes, but is not limited to, employees, agency workers, temporary staff, agents, contractors, external consultants, third-party representatives, and business partners.
This policy does not form part of any employee's contract of employment, and we reserve the right to amend it at any time.
In addition, C&R Software commits to the following specific safeguards:
- (a) No worker shall pay recruitment fees or related costs to obtain or keep a job ("no fees")
- (b) All workers shall be free to terminate employment with reasonable notice and without penalty
- (c) Workers shall retain control of their identity documents
- (d) The minimum age for employment shall meet or exceed the legal minimum in the country of work, and no hazardous work shall be performed by anyone under the age of 18
- (e) Overtime shall be voluntary and fairly compensated
- (f) Suppliers must cascade these requirements to their own supply chains
C&R Software recognizes that as a remote-first technology organization, our primary supply chain risks are concentrated in the areas of technology procurement, professional services, and contractor engagement rather than in physical goods manufacturing. We apply the same rigorous standards and due diligence processes to these areas as would be applied in any higher-risk physical supply chain context.
4.0 Responsibility for the Policy
The C&R Software Executive Board has overall responsibility for ensuring this policy complies with C&R Software's legal and ethical obligations, and that all those under our control comply with it.
The C&R Software HR Director has primary responsibility for implementing this policy. This includes responsibility for monitoring its use and effectiveness, auditing internal control systems and procedures, and updating the policy to reflect any changes in legislation.
Management at all levels of C&R Software are responsible for ensuring those reporting to them understand and comply with this policy.
C&R Software employees are invited to comment on this policy and suggest ways in which it might be improved.
Given C&R Software's fully remote structure, policy governance and oversight are maintained through regular virtual review cadences, digital audit trails, and centralized reporting systems. HR and GRC leadership collaborate to ensure that anti-slavery commitments are embedded consistently across all regions and operational functions.
5.0 Compliance with the Policy
All C&R Software employees and subcontractors must ensure that they read, understand, and comply with this policy. All C&R Software personnel are responsible for the prevention, detection, and reporting of modern slavery in any part of our business or supply chains. Employees are required to avoid any activity
that might lead to a breach of this policy or the Modern Slavery Act 2015.
Employees must notify their manager as soon as possible if they believe or suspect that a conflict with, or breach of, this policy has occurred or may occur in the future.
Employees are encouraged to raise concerns about suspicions of modern slavery in any part of our business or supply chains at the earliest possible stage.
Supplier Due Diligence
Prior to onboarding and periodically thereafter, C&R Software conducts risk-based reviews of suppliers considering:
- Country risk
- Sector risk
- Product/service risk
- Use of labour agents
- Past incident history
Where risk is elevated, we may require third-party audit reports, corrective action plans, or on-site/virtual assessments.
Contracts must contain:
- Anti-slavery clauses
- Audit and access rights
- Prohibition of recruitment fees
- Document-retention and cooperation clauses
- Termination rights for non-compliance
We classify supplier risk using our GRC methodology (Critical, Major, Moderate, Minor, Insignificant).
Higher-risk suppliers receive enhanced due diligence and more frequent monitoring.
Reporting Channels
Concerns can be raised via:
- Line management
- The Anti-Slavery Compliance Officer
- Anonymously through the Company's Speak-Up hotline
Non-retaliation applies to all good-faith reports.
Any suspected case must be escalated to the Anti-Slavery Compliance Officer within 24 hours for assessment and, where appropriate, notification to authorities and safeguarding partners.
As a fully remote organization, all supplier due diligence, risk assessments, and reporting activities are conducted through documented digital channels. C&R Software maintains centralized, auditable records of all supplier assessments and compliance activities, accessible to the GRC and HR teams in accordance with
the Company's data classification and retention policies.
Employees and contractors who identify potential indicators of modern slavery in any digital, virtual, or supply chain context — including through online procurement platforms, contractor management systems, or third-party vendor communications — are encouraged to report concerns immediately through the
channels listed above.
6.0 Communication and Awareness of this Policy
This policy is available on the C&R Software website.
Modern slavery training — which includes identifying signs of modern slavery and reporting suspicions of modern slavery within C&R Software supply chains — forms part of the induction process for all employees.
Refresher training will also be provided as necessary.
Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them. Suppliers are asked to comply with our Anti-Slavery and Human Trafficking policy from the onset of the relationship. Suppliers who are unwilling to
comply will not be onboarded.
All employees complete awareness training during onboarding and at least annually thereafter. Colleagues in higher-risk roles (for example, Procurement, Recruiting, Facilities/Operations) receive role-specific training and scenario exercises.
Suppliers must acknowledge this policy and, when requested, provide evidence of their own policies, training, and due-diligence processes.
We will publish an annual Modern Slavery Statement on our website that describes our structure, risks, due diligence, actions taken, training, and effectiveness measures for the prior financial year.
As a fully remote organization, all modern slavery awareness training is delivered through C&R Software's online learning platform (KnowBe4). Training completion rates are tracked centrally by HR and GRC, and records are maintained in accordance with the Company's record retention policy. This digital delivery
model ensures consistent and equitable access to training for all employees, regardless of geography or time zone.
C&R Software's annual Modern Slavery Statement will reflect the Company's remote-first operating model and will include specific commentary on how our digital and virtual ways of working inform our approach to
identifying and mitigating modern slavery risks in our supply chains.
7.0 Breaches of this Policy
Any employee who breaches this policy will face disciplinary action. This could result in action up to and including dismissal in accordance with the C&R Software Code of Conduct policy. We may terminate our relationship with other employees, suppliers, and any other associates working with C&R Software if they
breach this policy.
Upon identification of a breach or credible risk, C&R Software may:
- Require an immediate corrective action plan
- Suspend new work or payments
- Terminate contracts where appropriate
We will prioritize remediation for affected workers (for example, repayment of recruitment fees, restoration of freedom of movement, safe return or transfer) and cooperate with competent authorities.
Audit rights may be exercised to verify compliance, and failure to cooperate will be treated as a material breach.
Records related to due diligence, training, supplier assessments, and incidents will be retained for a minimum of seven years.
Key Performance Indicators
Key performance indicators used to measure the effectiveness of this policy may include:
- Training completion rates
- Number of supplier assessments conducted
- Remediation outcomes
- Number and resolution time of Speak-Up reports