Modern Slavery Policy

Slavery and Anti Human Trafficking Statement 2023

At Cleerly we are totally dedicated to upholding ethical employment practices. We are highlighting our commitment to creating procedures and policies that prevent slavery and human trafficking in our business dealings by releasing this policy.



This declaration outlines Cleerly's efforts to identify any risks associated with modern slavery that may affect its operations and to implement measures meant to guarantee that neither human trafficking nor slavery exist within the company's operations nor its supply chains. The activities that took place between 01 January 2023, and 31 December 2023 are covered by this statement.

At Cleerly, we aim to approach the fight against modern slavery in the same way that we approach providing outstanding customer service. As a result, we are dedicated to stopping human trafficking and slavery in business operations and making sure that supply chains are free of these harms. This encompasses looking for new ways to tackle modern slavery, and really challenge everyone we interact with to take action. That’s why we welcomed the Independent Anti-Slavery Commissioner’s review within the financial services sector on ‘Preventing Modern Slavery and Human Trafficking’. We are reviewing the outputs of the recommendations and will evolve our approach, aligned to these.

During the next year, our focus will be on educating our people, and equipping them with the tools to best support the customers, businesses and suppliers we work with.


Organisational structure

Cleerly was first established in 2020 as ‘Professional Contractor Mortgages’, a privately owned company that served professional freelancers and contractors. As the purpose of the company broadened to serve a wider cohort of professionals outside of just contractors, the firm rebranded to ‘Cleerly’ in February 2024. Cleerly has grown quickly to provide expert mortgage advice to those with complex incomes, helping their clients to navigate through the thousands of mortgages available in the market, removing barriers for professionals who cannot prove all of their income easily.

The aim of the firm and its management is to provide an efficient and client-centric mortgage advice process to busy professionals to allow them to achieve their aims of property ownership through competitive mortgages.

The company's policy is to retain a strong corporate identity and culture in order to draw in top talent and consumers and create long-term value for the company. The Company is dedicated to offering the best possible, well-researched mortgage and insurance advice that is user-friendly, professional, and efficient. The Company currently has offices in Whiteley, Hampshire.


Supply chain and Supplier Due Diligence

The supply chains used by Cleerly mostly deal with hiring, buying materials, equipment, and office supplies, as well as offering professional and support services, mostly in the areas of marketing, IT, finance, and legal/regulatory. We aim to collaborate with providers who are well-known and trustworthy in the financial services industry and who demonstrate adherence to anti-modern slavery laws.

To bolster our claim, we seek to establish partnerships with reliable suppliers to guarantee that standards for corporate conduct are unambiguous and uniform. Additionally, we anticipate that our direct suppliers will have appropriate anti-slavery and anti-human trafficking protocols in place.

In terms of HR practices, we deal with carefully chosen and reliable third parties to source employees and have strict identity and background checks in place, including policies and procedures for the following:

  • Anti Bribery and Corruption policy
  • Whistleblowing policy
  • Grievance policy
  • Health and Safety policy
  • Anti Money Laundering and Counter Terrorist Financing Policies
  • Equal Opportunities procedures in Recruitment and Onboarding Policies


Modern Slavery Risk Assessment

Even though we believe that Cleerly is still low risk in terms of modern slavery due to the nature of our business, we are still watchful and are giving close attention to the aspects of our operations when assessing the danger of modern slavery.

Although our supply chain is entirely sourced from the UK, it is possible that outsourced services like software development and IT support will be provided from abroad.

As our firm expands, we are using employment agencies more frequently to hire people on a temporary and full-time basis.



According to the Modern Slavery Act, colleagues must think carefully about their relationships with other businesses and remain vigilant about the potential for human trafficking and/or slave labour. In order to inform staff members about the dangers of modern slavery, we are now creating awareness around our Modern Slavery stance as summarised in this statement.


Measuring Effectiveness

While we continue to build these processes, they will be reviewed frequently to make sure that the following requirements are satisfied before the next statement is released.

  • Introducing a modern slavery training module for staff members that will cover the fundamentals and be given to individuals in charge of interacting with suppliers. This will provide our employees with the knowledge and skills they need to help our suppliers and customers to the fullest extent possible.
  • Concerns, hazards, and complaints about human trafficking and modern slavery are monitored, reported to senior management, and addressed.

Clauses addressing third parties' obligations will be included in all new contracts with suppliers.


Monitoring and Reporting

A Company Director shall be notified if any problems relating to modern slavery or human trafficking are found.

The Executive Management will be notified of any more general problems with the way the statement is operated.

The Board of Directors of the company has adopted this statement, which they will review and update every year.