CSR Policy

Harrrison Clarke’s Corporate Social Responsibility Policy

Introduction and values

1. Harrison Clarke is a recruitment company that specializes in Cloud, Data and Artificial Intelligence. With a highly committed team of market experts, our goal is to provide both clients and candidates an exceptional service, by helping companies achieve their hiring needs and identifying a unique and life changing opportunity for candidates.

2. At Harrison Clarke we believe these six values define the triangle of professional success that exists between client, candidate and recruiter:

Transparency – Radical transparency is essential to success in our relationships with our clints, candidates and colleagues.
Respect – We appreciate individuals’ unique talents and honor diverse life and work styles. We operate in a spirit of cooperation and value human dignity.
Expertise – We pride ourselves on being subject matter experts on the space we operate in.
Integrity – We seek and embrace the highest levels of conduct, behavior and ethics in our company. We understand this is the hallmark of good business.
Loyalty – We embrace the principles of commitment, support and allegiance.
Guidance – We pave the way to achieve unparalleled success empowered by our expertise in recruitment and in the Cloud, Data and Artificial Intelligence marketplace.

3. Our reputation is key to the trust that our working partners have in us and we maintain this reputation by providing all our clients and candidates with a high level of service acting in accordance with our values at all times and adhering to our carefully drafted Corporate Social Responsibility Policy. We expect all of our staff, partners, vendors, clients and suppliers to conduct their businesses ethically and lawfully and that they respect the principles that we set out in our Corporate Social Responsibility Policy. Our Corporate Social Responsibility Policy is made up of the following policies:

i. Diversity and Inclusion Policy;
ii. Anti-Corruption Statement – A message from Harrison Clarke’s CEO;
iii. Anti-Corruption and Bribery Policy; and
iv. Anti-Modern Slavery Policy

4. As well as our Corporate Social Responsibility Policy, we also consider compliance with the data protection requirements set out under EU Data Protection Laws (such as the General Data Protection Regulation 2016/679), UK data protection laws (such as the Data Protection Act 2018) and US data protection requirements (such as the Privacy Shield mechanism) of key importance to our business. As such, our employees are required to comply with our Privacy Policy and any failures to do so are dealt with under the Company’s disciplinary procedure and, in serious cases, may be treated as gross misconduct leading to summary dismissal. Our Privacy Policy can be accessed here https://www.harrisonclarke.com/privacy-policy/.

5. If you have any cause to believe that Harrison Clarke or any employee or agent of Harrison Clarke has behaved unethically or unlawfully in its business dealings or services provided, you are encouraged to report such behavior to Harrison Clarke, by contacting us via our website: https://www.harrisonclarke.com/contact-us/.

Harrison Clarke’s Diversity And Inclusion Policy

1. Diversity and Inclusion statement

Harrison Clarke is committed to promoting equal opportunities, equality, diversity and inclusion. Any individuals that we work with including our clients, customers, suppliers, vendors, candidates and employees receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, color, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics).

2. About this Diversity and Inclusion Policy

2.1. This Diversity and Inclusion Policy sets out our approach to equal opportunities and the avoidance of discrimination towards any individuals, to promote equality diversity and inclusion. It applies to any individuals that we work with or for.

2.2. This Diversity and Inclusion Policy does not form any part of a contract and we may amend it from time to time.

3. Who is responsible for this Diversity and Inclusion Policy?

3.1. Our CEO, Firas Sozan has overall responsibility for the effective operation of this policy and for ensuring compliance with discrimination law. Day-to-day operational responsibility for this policy also lies with all of our employees.

3.2. All staff members of Harrison Clarke, including managers and employees, are expected to set an appropriate standard of behavior, lead by example and ensure that they adhere to this Diversity and Inclusion Policy and promote our aims and objectives with regard to equal opportunities. We give appropriate training on equal opportunities awareness and equal opportunities best practice.

3.3. We also have an Internal Equal Opportunities Policy related to the avoidance of discrimination at work which applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures and termination of employment, to ensure that we promote equality, diversity and inclusion both internally and externally.

3.4. This Diversity and Inclusion Policy is reviewed annually. If you have questions about the application of this Diversity and Inclusion Policy, you should contact us via our website: https://www.harrisonclarke.com/contact-us/.

4. Discrimination

4.1. All members of Harrison Clarke are required to not unlawfully discriminate against or harass other people. We expect the same behavior from our clients, candidates, suppliers, vendors and other business partners.

4.2. The following forms of discrimination are prohibited under this Diversity and Inclusion Policy and are unlawful:

(a) Direct discrimination: treating someone less favorably because of a Protected Characteristic. For example, refusing to work with an individual because of their religious views or because they might be gay.

(b) Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others, and is not justified. For example, requiring a candidate to send a photograph without any head or face coverings might be indirect discrimination to people who cover their heads for religious reasons. Such a requirement would be discriminatory unless it can be justified.

(c) Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.

(d) Victimization: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.

(e) Disability discrimination: this includes direct and indirect discrimination, any unjustified less favorable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.

5. Anti-harassment and bullying

5.1. Harrison Clarke is also committed to promoting an environment which is free from harassment and bullying, and ensuring all of our candidates, clients and suppliers are treated with dignity and respect.

5.2. Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment and harassment also includes treating someone less favorable because they have submitted or refused to submit to such behavior in the past. A person may be harassed even if they were not the intended “target”, for example, a person maybe harassed by racist jokes about a different ethnic group if the jokes create an offensive environment. It may be sexual harassment, or may be related to age, disability gender reassignment, marital or civil partner status, pregnancy or maternity, race, color, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Harassment is unacceptable even if it does not fall within any of these categories.

5.3. Bullying can take the form of physical, verbal and non-verbal conduct. Bullying may include, by way of example:

(a) physical or psychological threats;

(b) overbearing and intimidating levels of supervision; or

5.4. If you feel you are being harassed or bullied in your dealings with Harrison Clarke, you should contact us via our website: https://www.harrisonclarke.com/contact-us/.

5.5. We always ensure that anyone who makes complaints or who participates in good faith in any investigations must not suffer any form of retaliation or victimization as a result.

6. Internal procedures

6.1. We have a number of procedures in place internally, to ensure that we are able to adhere to this Diversity and Inclusion Policy. These basic principles are set out below, and we expect that any company or business we provide our services to or otherwise do business with, complies with these principles.

Recruitment, promotion, selection of candidates, creation of relationships with clients, enlisting of suppliers, advertising and other such business considerations are conducted on the basis of merit, against objective criteria that avoid discrimination, harassment and bullying. Shortlisting should be done by more than one person if possible. Harrison Clarke will not tolerate requests from to deviate from this process when supplying its recruitment services.
Harrison Clarke expects that all vacancies should generally be advertised to a diverse section of the labor market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying.
Harrison Clarke expects that candidates, clients, suppliers and other such individuals should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic.
Harrison Clarke expects that clients and suppliers should not be asked about health or disability generally, and candidates and employees should not be asked about health or disability before a job offer is made, except in the very limited circumstances allowed by law: for example, to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability. Where necessary, job offers can be made conditional on a satisfactory medical check. Health or disability questions may be included in equal opportunities monitoring forms, which must not be used for selection or decision-making purposes. We will never use any information provided to us in order to discriminate against or bully an individual and expects the individual and companies we have dealings with to also adhere to this principle.

7. Disabilities

If you are disabled or become disabled, we encourage you to tell us about your condition so that we can consider what reasonable adjustments or support may be appropriate.

8. Breaches of this Diversity and Inclusion Policy

8.1. Harrison Clarke takes a strict approach to breaches of the values and requirements set out in this Equal Opportunities Policy, which will be dealt with internally in accordance with our internal disciplinary procedures. Serious cases of deliberate discrimination conducted by our employees may amount to gross misconduct resulting in dismissal. Where this is conducted by our business partners, this may result in us seeking to terminate that business relationship.

8.2. If you believe that you have suffered discrimination involving Harrison Clarke please contact via our website: https://www.harrisonclarke.com/contact-us/. Complaints will be treated in confidence and investigated as appropriate. You will not be victimized or retaliated against for complaining about discrimination, other than in cases of false complaints which might be dealt with accordingly.

Harrison Clarke’s Anti-Corruption Statement

A message from Firas Sozan, CEO of Harrison Clarke

Harrison Clarke is a recruitment company that specializes in the Cloud, Data and Artificial Intelligence space. With a highly committed team of market experts, our goal is to provide both clients and candidates an exceptional service, by helping companies achieve their hiring needs and identifying a unique and life changing opportunity for candidates. We operate around the world especially in the UK and the US, and we pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity throughout our organization.

Harrison Clarke condemns corruption in all its forms and we will not tolerate it in our business or in those we do business with. From the confines of our working environments, it is sometimes difficult to grasp the scale of the damage that bribery does to societies. It is not a victimless crime; far from it:

“Corruption … undermines democracy and the rule of law, leads to violations of human rights, distorts markets, erodes the quality of life and allows organized crime, terrorism and other threats to human security to flourish. This evil phenomenon is found in all countries – big and small, rich and poor…corruption hurts the poor disproportionately by diverting funds intended for development, undermining a government’s ability to provide basic services, feeding inequality and injustice and discouraging foreign aid and investment. Corruption is a key element in economic under-performance and a major obstacle to poverty alleviation and development.” (Kofi Annan, former UN Secretary General).

Our Anti-Corruption and Bribery Policy sets out in detail how our employees and the companies and individuals we work with are expected to behave and what you should do if you are confronted with corruption. We expect that all of the individuals and companies that we work with will embrace the Anti-Corruption and Bribery Policy and its values and use them in all aspects of their day-to-day work.

The Anti-Corruption and Bribery Policy is for your benefit as much as for Harrison Clarke’s. If convicted of a bribery offence, Harrison Clarke or any company involved might get a significant fine and suffer lasting reputational damage. If an employee or an individual working with us is convicted of a bribery offence, they could face a prison sentence. The potential harm done by bribery, both to Harrison Clarke and to you as an individual, is long term and hugely outweighs any potential short term gain. Bribery is just not worth the risk. We run our business with integrity. All of us must work together to ensure that they remain untainted by bribery or corruption in any form. We are therefore putting in place this Anti-Corruption and Bribery Policy to make sure that happens. The Anti-Corruption and Bribery Policy, which has the full support of our organization, is my responsibility. But it needs your full support to make it work. In all our interests, please read it thoroughly, and give it that support.

If you have any doubts about anything at all, refer to the Anti-Corruption and Bribery Policy or you can speak to me in complete confidence. We are committed to eradicating corruption and we will stand by you in acting ethically, whether you are an employee, partner, client, candidate, supplier or vendor.

Firas Sozan, CEO of Harrison Clarke

Date: 01.12.2020

Harrison Clarke’s Anti-Corruption And Bribery Policy

1.Introduction

1.1 Bribery and corruption remain major issues in world trade, despite the many dedicated efforts to prevent them. They are very damaging to the societies in which they occur. They:

(a) divert money and other resources from those who need them the most;

(b) hinder economic and social development; and

1.2 Our legal obligations are primarily governed by the Bribery Act 2010 (BA 2010) and the Foreign Corrupt Practices Act 1977 (FCPA 1977). BA 2010 and FCPA 1977 affect us as an organization with business in the UK and the US if bribery occurs anywhere in our business.

1.3 We run our business with integrity and in an honest and ethical manner. All of us must work together to ensure it remain untainted by bribery or corruption.

1.4 This policy is a crucial element of that effort. It has the full support of the CEO of Harrison Clarke and the business. It sets out the steps all of us must take to prevent bribery and corruption in our business and to comply with relevant legislation.

2. Questions

If you have any questions on this policy, please contact via our website: https://www.harrisonclarke.com/contact-us/.

3. Bribery, corruption and facilitation payments

3.1 Corruption is the misuse of office or power for private gain. It is illegal in the UK and in the US.

3.2 Bribery is a form of corruption. It includes offering, promising giving, accepting or seeking a bribe. A bribe is a financial or other advantage, promised, requested or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so. In practical terms, a financial or other advantage is likely to include cash or cash equivalent, gifts, meals, entertainment, services, loans, preferential treatment, discounts or anything else of value. The timing of the bribe is irrelevant and payments made after the relevant event will still be caught, as will bribes that are given or received unknowingly.

3.3 In the UK under the BA 2010 it is illegal for bribery to take place between any two individuals. Whilst in the US the FCPA 1977 prohibits bribery involving foreign officials, such conduct may be addressed under other US statutes. As an international organization, we apply the highest standards of protection and, therefore, any and all forms of bribery and corruption are prohibited.

3.4 It is not necessary for the individual, foreign official or organization to actually receive any benefit as a result of the bribe. This means that you must not, for example:

(a) give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received, or to reward any business received (“active bribery”);

(b) accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else (“passive bribery”);

(c) give or offer any payment to a government official in any country to facilitate or speed up a routine or necessary procedure; or

(d) give or offer anything of value to a non-US public official or a closely related individual of the non-US public official, or any other person with knowledge that they might give or offer anything of value to a non-US public official or closely related individual, for the purposes of improperly influencing any act or decision of the non-US public official in their official capacity, inducing them to do, or omit to do, any act in violation of his/her lawful duty, or improperly induce them to use their influence with the government or department, agency or instrumentality to affect or influence any act of decision, in order to secure an improper advantage to which we are not entitled (including a decision to purchase our services, a contract award or a grant of operating permits or business licenses).

3.5 In the UK under the BA 2010 both active and passive bribery are prohibited, while the FCPA 1977 covers only the active bribery of foreign officials. As an international organization, we apply the highest standards of protection and, therefore, both forms of bribery are prohibited.

3.6 No person must threaten or retaliate against another person who has refused to offer or accept a bribe or who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

3.7 In some countries, it might be the local business practice to make small payments to low-level non-US public officials to facilitate or expediate a routine governmental action, known as facilitation payments. It is difficult to distinguish between facilitation payments and a bribe, so such payments will only be permitted in extremely limited circumstances and must be reported in advance to the CEO of Harrison Clarke. The only exception to this is if there is an imminent threat to the health or safety of an employee, for example if they are stopped by police, military or paramilitary personnel and payment is demanded, however this must then be immediately reported to our CEO.

4. Who can be involved in bribery and in what circumstances?

4.1 Bribery and corruption may be committed by our:

(a) staff (employees, directors etc) or anyone they authorize to do things on our behalf

(b) representatives and other third parties who act on our behalf

(d) clients (because they might try to induce one of our people to give them more favorable terms)

4.2 In the UK, bribery can occur in both the public and private sectors. The person receiving the bribe is usually in a position to influence the award or the progress of business, sometimes a government or other public official. In the US, corruption is only prohibited towards foreign public officials, however, we apply the highest standard of protection across our business and prohibit all forms of corruption and bribery between private and public individuals.

5. The legal position on bribery

5.1 Bribery and corruption are criminal offences in most countries where we do business. UK businesses, including this one, are subject to BA 2010. Under BA 2010 it is illegal to:

(a) pay or offer to pay a bribe;

(b) receive or agree to receive a bribe; or

5.2 US businesses, including Harrison Clarke International Inc., are subject to the FCPA 1977. Under the FCPA 1977 it is illegal to:

(a) bribe foreign officials, a foreign political party, an official of a foreign political party, or a candidate for a foreign political office in order to influence any act or decision, or induce the person to do or omit any act in violation of their lawful duty, to secure an improper advantage corruptly; or

(b) be willfully blind to signs of corruption through our agents.

5.3 A commercial organization can also commit an offence if a person associated with it bribes another and does so with the intention of obtaining or retaining business or a business advantage for the organization.

5.4 At Harrison Clarke, we consider that it does not matter whether the bribery or corruption occurs in the UK, US, or abroad. An act of bribery or corruption committed abroad may well result in a prosecution in the UK and/or the US. Nor does it matter whether the act is done directly or indirectly. We prohibit any and all forms of bribery and corruption.

6. Harrison Clarke’s position on bribery

6.1 Our position is simple: we conduct our business to the highest legal and ethical standards. We will not be party to corruption or bribery in any form. Such acts would damage our reputation and expose us, and our staff and representatives, to the risk of fines and imprisonment. We take a zero-tolerance approach to bribery and corruption by our people and our third party representatives.

6.2 Bribery and corruption may be more widespread in some countries and business sectors than others. In some cases we may be told that unless we pay bribes we will not win business. That does not matter. If we were to be involved in even one instance of bribery or corruption, we would have shown that we engage in such conduct. We do not.

7. Local customs

We understand that people in different parts of the world have different social and cultural customs. This does not affect our stance that we do not pay or accept bribes or act corruptly: we do not and will not. However, subject to that position and to the position on facilitation payments described above, we understand the need to be sensitive to local customs, e.g. that there are some cultures in which refusing (or failing to offer) a gift is considered impolite and could alienate a key contact or client. In such cases, please contact via our website: https://www.harrisonclarke.com/contact-us/.

8. Consequences of failing to comply

8.1 We take compliance with this policy, the principles it sets out and the applicable laws very seriously. Failure to comply puts both the individual and the business at risk.

8.2 Individuals may commit a criminal offence if they fail to comply with this policy and are a member of our business or are involved in business dealings with us. The criminal law in the UK and the US relating to bribery and corruption carries severe penalties.

8.3 Because of the importance of this policy, failure to comply with any requirement by our employees may lead to disciplinary action under our procedures, and this action may result in dismissal for gross misconduct. Failure to comply by our business partners may result in our business relationship being terminated.

8.4 If you have any questions or concerns about anything in this policy, please contact via our website: https://www.harrisonclarke.com/contact-us/.

Harrison Clarke’s Anti-Modern Slavery Policy

1. Introduction

1.1. Harrison Clarke is making a voluntary modern slavery and human trafficking statement relating to section 54 of the Modern Slavery Act 2015.

1.2. We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that there is no slavery or human trafficking in our business or in our supply chains.

2. About us

2.1. We are Harrison Clarke, a recruitment company that specializes in the Cloud, Data and Artificial Intelligence space. We operate around the world especially in the UK and the US, and we pride ourselves on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity throughout our organization.

2.2. Our annual turnover is under £36 million and under $47 million. Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we have created this Anti-Modern Slavery Policy to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains .

2.3. Our supply chains are made up of the following:

(a) candidates;

(b) clients; and

2.4. We are committed to ethical trading principles and to acquiring goods and services without harm to others.

3. Modern slavery and human trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labor, bonded and child labor and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

4. Commitments

4.1. We have zero-tolerance for modern slavery in our organization or supply chain.

4.2. The prevention, detection and reporting of modern slavery in any part of our organization or supply chain is the responsibility of all those working for us or on our behalf. Our workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

4.3. We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

5. Due diligence and risk assessment

5.1. To help identify and monitor the risk of slavery and human trafficking in our supply chain we contractually require all those who we engage in business with to promise that they will follow the laws applicable to them including anti-modern slavery laws.

5.2. We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labor in our contracts with third parties. Using a risk based approach we also assess the merits of writing to suppliers to ask them to comply with this Anti-Modern Slavery Policy.

5.3. As part of our ongoing risk assessment and due diligence process we will consider whether circumstances warrant us carrying our audits of suppliers for their compliance with our Anti-Modern Slavery Policy.

6. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff.

7. Enforcement

If we find that any individuals or organizations working on our behalf have breached this policy we will ensure that we take the appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those impacted by the breach to terminating such relationships.

This voluntary Anti-Modern Slavery Policy is made in connection with section 54(1) of the Modern Slavery Act 2015, for the financial year ending 2020. It was approved by our CEO on 01.12.2020.

Firas Sozan, CEO of the Harrison Clarke Group