Clearsulting’s Modern Slavery and Human Trafficking Policy

About this policy

The purpose of this policy is to set out Clearsulting’s expectations and commitments in accordance with the Modern slavery Act 2015, The Fair Labor Standards Act (FLSA), and to align with global modern slavery and anti-trafficking protections. Clearsulting has a zero tolerance for slavery and human trafficking in any part of our business.

Policy statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor 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 human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships. Clearsulting has a number of practices in place to ensure all our team members have the right to work and are paid fairly, that we act with integrity and ethically, and that we have effective measures in place to ensure slavery is not present anywhere in our business.

This policy applies to all team members of Clearsulting. Including, all positions within the firm, contractual third parties, or partners doing business with the firm.

Organizational structure

Clearsulting is a management consulting firm that partners with global organizations to provide professional services. Founded and headquartered in Cleveland, Ohio, we operate across North America and Europe, and specialize in digital reporting, enterprise performance management, finance effectiveness, financial close, risk advisory, and treasury services. We solve finance leaders’ toughest problems by fostering a joyful, trusting work environment, delivering a select set of expert digital capabilities, and instilling sustainable improvement for our clients and ourselves. Our mission is to spark innovation by thoughtfully advising finance leaders, streamlining processes, and advancing technology.

While Clearsulting does not function with a supply chain and solely provides professional services, we recognize the protentional modern slavery risks related to our business and are taking steps to enforce the following responsibilities throughout all facets of our firm.

Responsibility

Clearsulting is committed to uphold the rights of our team members and treat them with dignity and respect. We have detailed processes and procedures in place to ensure we are in compliance with all federal, state, and local regulations and laws. Clearsulting has adopted the following principles to reinforce its value of treating all people with dignity and respect:

Clearsulting will not tolerate the use of child or forced labor in any of its global operations. We will not tolerate the exploitation of children, their engagement in unacceptably hazardous work, and the physical punishment, abuse, or involuntary servitude of any worker. For purposes of these Principles, a “child” is anyone who is less than 18 years of age.
Clearsulting supports temporary workplace internship and apprenticeship education programs for younger persons as well as customary seasonal employment so long as such persons are closely supervised and their morals, safety, health, and compulsory education are not compromised in any way.
Work weeks do not exceed the maximum set by federal, state, or local law (whichever is greatest).
Compensation paid to employees is compliant with all applicable wage laws, including those related to minimum wages, overtime hours, and legally mandated benefits.
In compliance with local laws, employees are compensated for overtime at pay rates greater than regular hourly rates where applicable.
Verification of employment eligibility is always performed per federal and state laws.
Creation and maintenance of team member documents and records ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
The Human Resources department conducts a regular review of our processes related to wage and labor practices and stays up to date with ever evolving laws.

It is the responsibility of both leadership and the Human Resources department to implement and ensure compliance with these principles in each location where we do business. We expect the clients and contractors with whom we do business to uphold the same standards.

Compliance

Clearsulting is committed to ensuring that the use of modern slavery and/or human trafficking does not exist in any part of our business. As part of our initiative to identify and mitigate risk, we encourage all our team members to raise concerns about any issue or suspicion of modern slavery and/or human trafficking.

Clearsulting upholds a strict whistleblowing policy to protect those who come forward with concerns of violations of this policy. It is the duty of all Clearsulting team members to report known violations of this policy and to not take part of any modern slavery or human trafficking acts as described in the policy statement section above.

Serious concerns of illegal or unethical behavior and violations of this policy should be reported promptly to the Human Resources department. Reports should be submitted in written form either through email or physical letter.

If a whistleblower does not feel comfortable reporting a serious concern or violation to the Human Resources department or their manager, the whistleblower should contact ADP MyLifeAdvisor support line at +1 855-547-8508. MyLifeAdvisor is a third-party confidential reporting line operating from 8:00am – 11:30pm ET.

As mentioned in Clearsulting’s Whistleblower Policy, all reports will be investigated in a timely manner and appropriate corrective action will be recommended to necessary parties, if warranted by the investigation. Any team member who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.