This statement sets out Comparison Technologies Ltd (CTL) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its partnerships.

This statement relates to actions and activities during the financial year 1st April 2019 to 31st March 2020.

As part of the Telecom’s & IT industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Risk Management

The organisation currently operates in the following countries: U.Kand India.

Risks are managed in accordance with the risk register.

All employees in the UK are paid at least the UK National Living Wage and within India all terms and conditions are transparently communicated via the equal opportunities committee.  All terms and conditions are available to all employees via the employee handbook.

All relevant employment contracts and terms and conditions are managed consistently across the group by the HR department.

All agency workers/employees/third party employees are all also UK based and therefore subject to UK legislation.  There are no agency workers in India.


Responsibility for the organisation’s anti-slavery initiatives falls to the COO.

Responsibilities are ultimately for the following areas:

  • Health & safety
  • Ethical business practices
  • Risk assessments
  • Investigations of poor practise
  • Due diligence
  • Training

Relevant policies

Policies The organisation has the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations

Dignity at Work policy The company is committed to creating a work environment free of harassment and bullying, where everyone is treated with dignity and respect.

Whistleblowing policy This policy applies to all employees and directors of the company. Other individuals performing functions in relation to the company, such as agency workers and contractors, are also encouraged to use it.

Anti-Bribery Policy The company is committed to applying the high standards of ethical conduct and integrity in its business activities in the UK and overseas. Every employee and individual acting on the company’s behalf is responsible for maintaining the company’s reputation and for conducting company business honestly and professionally.

Ethical Business Policy Achieving our mission means driving progress for people; being a successful and responsible long term ethical business, trusted by customers and supporting healthy people and their environment.

Third parties:

Supplier code of conduct

The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.

The organisation works with suppliers to ensure that they meet the standards of the code and maintain good working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

Agency Workers

The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

The organisation undertakes due diligence when considering working with new suppliers, and regularly reviews its existing suppliers.

Where suppliers are unable to satisfy us that they comply with this Act then CTL will ascertain whether there is sufficient concern to replace or appoint them.


To ensure a high level of understanding of the risks of modern slavery and human trafficking, we have provided training that all employees are required to undertake.

Peter Callander, Chief Operating Officer

July 2019