This first statement in accordance with Section 54 of the United Kingdom’s Modern Slavery Act, 2015 is made on behalf of Clickatell Corporation and its subsidiaries (herein after “Clickatell”) for the financial year ending December 2022. This statement sets out the measures implemented by Clickatell to prevent the occurrence of slavery and human trafficking within its supply chain. 

Organisational structure and supply chains 

Clickatell comprises of its holding company, Clickatell Corporation, a Delaware corporation incorporated on 27 March 2008, and its subsidiaries, namely:

Clickatell provides mobile communications and chat commerce solutions in the form of Platform-based Software as a Service (SaaS) digital integrations with its customers. As such, the supply chain consists mainly of Telecommunication Providers, IT and communications equipment and services, digital marketing service providers and external company secretarial firms. 

Company policies 

Modern Slavery Policy

Clickatell recently adopted an internal Modern Slavery Policy (“Policy”) to ensure that its employees are made aware of and comply with the human rights obligations in respect of the prevention and combatting of modern slavery.

Whistleblowing policy

In accordance with the Whistle blowing Policy, employees, vendors and all interested parties who believe or are aware of breaches to any Clickatell policies, including the Policy, are encouraged to report such violation through either the external whistleblowing line or internally to the Legal department. To date, no reports of any such violations have been received.

Due diligence and risk management 

The Human Resources department ensures that the appropriate level of due diligence is conducted on prospective employees. This includes verifying the prospective employees’ documents and contacting their references. 

Key performance indicators to measures effectiveness of steps being taken 

The first step taken by Clickatell was the adoption of an internal policy outlining the commitments and measures that it has and will continue to implement to prevent and/or minimize the risk of human trafficking and slavery taking place within the group of companies and its supply chain. 

The proposed next steps for the coming financial year include:

Training on modern slavery and trafficking 

The Policy has been made available on Clickatell’s policy housing platform and all existing employees are required to familiarize themselves with the content thereof. 

Training on the Policy and Clickatell’s commitments will be carried out during the onboarding process of all new employees. 

This statement has been approved by the Social and Ethics Committee on behalf of Clickatell.