Modern Slavery Act 2015 Transparency Statement

Clarence Legal Limited

This statement is made voluntarily in the spirit of Section 54 of the Modern Slavery Act 2015, and sets out the steps Clarence Legal Limited has taken to understand and address the risk of modern slavery and human trafficking in our business and supply chains.

Although Clarence Legal Limited falls below the £36 million turnover threshold that triggers the mandatory transparency reporting requirement, we are committed to adopting this statement to demonstrate our values and support responsible supply chain practices across our industry.

1. Organisation's Structure, Business and Supply Chains

Clarence Legal Limited is a UK-registered legal technology company that develops and provides AI-powered legal tools to law firms, legal professionals and businesses. We are based in the United Kingdom and operate as a services-only business with no physical supply chain or goods procurement.

The company is currently structured with three directors and operates from a home office. We have no employees at this stage; our service delivery is managed by the director team. Our business model is entirely digital, with no reliance on physical goods, manufacturing, or logistics partners.

Given our services-only model and the absence of a traditional supply chain, our exposure to modern slavery risk is minimal. However, we remain alert to potential risks in any future expansion or engagement with third-party service providers.

2. Policies in Relation to Slavery and Human Trafficking

Clarence Legal Limited is committed to the highest ethical standards in all our business dealings. We do not tolerate slavery, human trafficking, forced labour, or any form of labour exploitation in any part of our business or supply chains.

Our policy position is clear:

• We will not knowingly engage with suppliers, partners, or service providers who exploit workers or breach labour rights.
• We comply with all applicable UK employment law and expect the same of any third parties we work with.
• We respect the dignity, rights and welfare of all individuals involved in our business.
• Any future recruitment or engagement of staff or contractors will be conducted fairly, transparently and in full compliance with employment law.
• We will not use forced labour, bonded labour, or child labour under any circumstances.

This commitment is embedded in how we operate and is reinforced through our director-led governance.

3. Due Diligence Processes

Our due diligence approach is proportionate to our size and risk profile:

• Supplier and partner engagement: Before engaging any third-party service provider (such as IT support, accounting, or legal referral partners), we assess their reputation, credentials and ethical standing.
• Contractual terms: Any service agreements we enter into will include clauses requiring compliance with employment law and ethical business practices.
• Ongoing monitoring: We maintain awareness of the practices of any partners we work with and will take action if concerns arise.
• Internal governance: Our small director team ensures oversight of all business decisions and relationships.

As our business grows and our supply chain becomes more complex, we will strengthen and formalise these processes accordingly.

4. Risk Assessment and Management

We have assessed the modern slavery risk profile of Clarence Legal Limited as low, based on:

• Our services-only business model with no physical supply chain or goods procurement.
• Our current structure as a director-led team with no employees.
• Our operation from a UK-based home office with full compliance with UK employment law.
• Our digital-first service delivery with no reliance on labour-intensive processes or offshore operations.

However, we recognise that risk can evolve. We will monitor our risk profile as the business develops, particularly if we:

• Recruit employees or engage contractors.
• Expand our service offerings or geographic reach.
• Establish relationships with new suppliers or partners.

Should any risks emerge, we are committed to addressing them promptly and transparently.

5. Key Performance Indicators

Given our current size and low-risk profile, we do not yet have formal KPIs for modern slavery prevention. However, we track the following indicators as our business develops:

• Number of employees and contractors: Currently zero; any future recruitment will be conducted fairly and in full compliance with employment law.
• Supplier and partner relationships: Currently minimal; we will monitor and assess any new relationships against our ethical standards.
• Complaints and concerns: We maintain an open-door approach to any concerns raised by staff, partners or customers. Any allegation of modern slavery or labour exploitation will be investigated immediately.
• Training completion: As we grow, we will ensure all staff and directors receive appropriate training on modern slavery awareness and our commitment to ethical practices.

6. Training Available to Staff and Directors

Our director team is aware of the risks and indicators of modern slavery and human trafficking. We have reviewed the guidance published by the UK Government and the Gangmasters and Labour Abuse Authority (GLAA) to ensure we understand our responsibilities.

As Clarence Legal Limited grows and we recruit staff or engage contractors, we will:

• Provide induction training on our ethical values and commitment to fair labour practices.
• Ensure all team members understand the signs of modern slavery and know how to raise concerns.
• Make available resources and support for anyone who suspects modern slavery or labour exploitation.
• Review and refresh training annually to reflect any changes in our business or supply chain.

Review and Approval

This statement is reviewed annually by the Board of Clarence Legal Limited to ensure it remains accurate and reflects our current business practices and risk profile. We are committed to continuous improvement in our approach to modern slavery prevention.

Approved and signed by:

John W. Hayward Director Clarence Legal Limited

Date: September 1, 2026

For more information about modern slavery, visit the UK Government's Modern Slavery Act guidance at www.gov.uk/guidance/modern-slavery-act-transparency-requirements