Modern Slavery Statement

Introduction 

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 30 June 2024. 

CloudCapcha Ltd (the ‘Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.  

Organisational structure 

CloudCapcha Ltd and has business operations in the United Kingdom, USA, Australia and the Republic of Ireland. 

We operate in the Accounting Firms sector providing SaaS tools for the automation of time recording and billing. 

In our supply chain we deliberately work with a few key direct suppliers, who provide us with services, such as outsourced business processes, cloud platforms and marketing services. 

For more information about the Company, please visit our website: www.cloudcapcha.com/about-us  

Policies 

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. 

These include the following: 

Recruitment and selection policy – Our policy is to only recruit full-time employees in those countries where we operate and where we have clients. Our selection criteria policy is to recruit only suitably qualified people whom we will pay at or above the median rate for that role in that territory. 

Where we use an outsourced supplier for technical resources, we will only engage with a Firm that has named dedicated resources, and whom we have met. 

We require visibility of the employee’s employment contract to confirm that their conditions of employment are of a similar or superior level to those which we operate with our own direct employees. 

All recruitment decisions are signed off by the CEO prior to the commencement of work. 

Staff code of conduct – As a Company operating in the Accounting Profession, we have a duty of care to our employees and our clients’ employees to conduct ourselves in a respectful and appropriate manner. 

The staff code of conduct makes it explicitly clear that we do not tolerate any behaviour which may be construed as encouraging or tolerating Slavery, Servitude, Forced or Compulsory Labour, Human trafficking or Child Labour in our own employees, our suppliers’ employees or our clients’ employees. 

We make sure our suppliers are aware of our policies and adhere to the same standards. 

Due Diligence 

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted Internal Supplier audits as part of our due diligence procedures. 

Our due diligence procedures aim to identify potential risks in our business and supply chains and reduce the risk of slavery and human trafficking occurring in our business and supply chains. 

Risk and Compliance 

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its supply chain through evaluating the slavery and human trafficking risks of each new supplier. 

We consider that we operate in a low-risk environment because the majority of our supply chain is based in the UK, EU or the USA and in low-risk industries, such as internet software and services provided by mostly publicly listed organisations, e.g. Microsoft. 

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately. 

Effectiveness 

The Company measures its effectiveness to ensure that slavery and human trafficking is not taking place in its business and supply chains.  

We carry out a regular audit of suppliers with a target of 50% of our suppliers each year chosen at random. 

This statement was approved by the Board of Directors on 26 August 2024