Modern Slavery Act Statement
Overview
Financial year ending 31 December 2025 Joint statement of CLARK Holding SE and CLARK Insurance UK Ltd under section 54 of the Modern Slavery Act 2015
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (“the Act”) by CLARK Holding SE (“CLARK” or “CLARK Group”) on behalf of itself and its UK subsidiary CLARK Insurance UK Ltd (formerly Candid Insurance Services Limited), which trades through the CLARK UK, TOM, Polly and Compare my Cover brands (“CLARK UK”). It is a joint statement covering both organisations and sets out the steps CLARK Group and CLARK UK have taken during the financial year ending 31 December 2025 to prevent and address modern slavery and human trafficking in their business operations and supply chains.
CLARK UK is a member of CLARK Group, which has its head office in Frankfurt am Main,Germany and operates in Germany, the United Kingdom, Switzerland and France; a service company in Spain supports the Swiss business. CLARK Group carries on business within the UK through its subsidiary CLARK UK and the brands TOM and Polly. CLARK UK also operates www.comparemycover.co.uk, a comparison website launched in 2026 that generates leads for life insurance and critical illness cover for customers who are looking to source cover outside of the TOM and Polly brands.
CLARK UK is an insurance broker and distributor, providing access to long term protection insurance services such as life insurance, income protection, critical illness insurance and accident and sickness cover through its own digital platforms including mobile apps and websites.
CLARK recognises that modern slavery is a violation of fundamental human rights and freedoms. CLARK 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 supply chain.
It is a priority for CLARK Group 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 its supply chain, the policies that underpin them, and the steps planned for 2026.
Speak Up Policy
The CLARK Group Speak Up Policy was introduced on 1 July 2023 and last updated on 3 July 2026 (version 1.5) 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, including the UK. It applies to CLARK UK and has replaced the former UK whistleblowing policy of Candid Insurance Services Limited.
Non-compliance with laws, regulations, internal standards and policies, if it occurs, is a serious risk to CLARK’s business, its customers and its reputation.
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 to confirm 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.
Violations of human rights within CLARK Group or its supply chain, which include modern slavery and human trafficking, are expressly listed in the Speak Up Policy as a reportable compliance concern.
Integrity Line 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, including suppliers and their workers, for the reporting of any compliance concerns.
All reports are treated confidentially and the identity of the reporting person is protected in line with the Speak Up Policy and applicable law.
The Speak Up Policy is approved by the Chief Legal & Compliance Officer and the CLARK Group Executive Committee and is reviewed annually.
Code of Conduct
“We are committed to acting with integrity and empathy in everything we do – for our customers, our partners, and our employees. By upholding the law and staying true to core ethical principles, we do more than meet expectations – we help protect what matters most in our customers’ world.”
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 living up to our ethical values.
The 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. It requires all employees to choose and check business partners carefully and to speak up about suspected misconduct.
Supply Chains
CLARK Group’s supply chains, in the UK and in its other markets, primarily include: suppliers of software and technology solutions, providers of office equipment, facilities and services (including outsourced cleaning), 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 in place across the Group. It includes sanctions and watchlist screening, checks for politically exposed persons and adverse media screening before a business partner is onboarded, and a classification of service providers by criticality and data protection risk under the CLARK Group Service Provider Policy. Since February 2026 the requirements for dealing with business partners are formalised in the CLARK Group Anti-Corruption Policy, which requires business partner engagements to be subject to risk-based due diligence, to be governed by written agreements containing appropriate compliance clauses including audit and termination rights where necessary, and to be monitored on an ongoing basis.
We treat our business partners fairly and expect them to hold to the same high compliance and ethical standards that we follow 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 broking 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. We have not yet carried out a specific review of the employment practices of our facilities and cleaning contractors; this is one of the steps planned for 2026 set out below.
The business operations are Europe-based and oriented to European customers without reliance on complex global supply chains. None of our software development contractors or outsourced customer service providers are located outside Europe.
Compliance
Where we find evidence that a supplier has failed to comply with our standards in respect of modern slavery, or has breached the law in this area, we will investigate and in the first instance require the supplier to remediate the issue within a defined period, so that affected workers are protected rather than displaced. Where remediation fails or the breach is serious, we will terminate the relationship. Where there is a suspicion of a breach, we will investigate and work with the supplier to establish the facts.
We expect the organisations in our supply chains to comply with all applicable laws, including the Act where it applies to them, and to have no modern slavery or human trafficking in their operations. Supplier contracts are concluded individually; our Anti-Corruption Policy requires them to contain appropriate compliance clauses, including audit and termination rights, where necessary. During 2026 we will extend our standard compliance clause to cover modern slavery and human trafficking expressly.
Our Policies
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 Policy as set out above, and we foster an open, inclusive and respectful culture in our everyday work, in our hiring and promotion practices and in our communication.
Our Employees (United Kingdom)
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. In 2024 we reviewed our third-party recruitment agencies’ practices. Within this review, we 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. The review was not repeated in 2025 and will be repeated in 2026.
Across the Group, employment in Germany, Switzerland and France is governed by the respective national labour laws, and the CLARK Group Code of Conduct and Speak Up Policy apply to all employees in all locations.
Training and Effectiveness
Training on the Code of Conduct and the Speak Up Policy is provided to employees under the CLARK Group Compliance Training Concept. In 2025 no report was received through the Speak Up channels that related to human rights, modern slavery or human trafficking.
Steps Planned for 2026
During 2026 CLARK Group intends to adopt a Group Policy on Business Partner Compliance that formalises risk-based due diligence and continuous monitoring of business partners across the Group and expressly includes forced labour and other human rights risks among the risk factors assessed; to extend its standard compliance clause for supplier contracts to cover modern slavery and human trafficking; to obtain written confirmation from its facilities and cleaning contractors on their employment practices; and to repeat the review of its third-party recruitment agencies in the UK.
This statement was endorsed by the CLARK Holding SE management board on 1st October 2026 and by the board of Candid Insurance Services Limited on 5th October 2026.