23rd April 2025
This Modern Slavery Statement is made by Croud Inc Ltd. on behalf of itself and those entities listed in our organisational structure below which operate as part of Croud Inc Ltd pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and constitutes our modern slavery and human trafficking statement for the financial year ending 31st March 2025. It sets out the steps that Croud have undertaken and are undertaking to ensure that modern slavery and human trafficking are not taking place in any of Croud’s supply chains.
Croud is committed to ensuring that modern slavery and people trafficking are not part of our supply chain. We hold ourselves to the highest professional standards and expect our suppliers to do the same. We do this through policies, assessments, processes and awareness training for all our staff.
Croud Inc Ltd is a company offering digital marketing solutions to clients globally.
Croud Inc Ltd, under company number 07542498, owns and operates the following UK entities: Verb Brands Ltd., Born Group Ltd., Born Social Ltd., Serpico Marketing Solutions Ltd. as well as entities outside of the UK Croud MENA DMCC and Croud Incorporated (USA). . Croud Inc Ltd. is owned by our holdings company Croud Holdings Ltd.
As an office based service company, Croud’s supply chain consists primarily of
Office suppliers will be those providing support with facility management, such as utilities, electricians, waste management, consumables.
Third party digital marketing suppliers are those that Croud uses to provide digital marketing services for our clients, such as paid search advertising, social media advertising.
Standard business operating suppliers might include law firms, accountants, information technology providers.
Croud has a modern slavery policy that is reviewed annually by our compliance team and forms part of both onboarding and annual awareness training. Information is also posted on our internal intranet site for employees.
Croud also operates contractual processes with suppliers to ensure that our supplier code of conduct is agreed and signed by the supplier prior to onboarding with our company.
In addition to Croud’s supplier code of conduct, Croud also requires all suppliers to respond to a self assessment questionnaire prior to onboarding. The self assessment questionnaire requires suppliers to provide information about their business operations, policies and practises to gauge their business maturity, compliance with law, security posture as well as whether there could be any risk of modern slavery through the appointment of the supplier.
Croud has a contracts and compliance team who actively ensure that suppliers sign our code of conduct (or provide their own where it aligns with Croud’s to a materially similar standard. The team also feeds in contractual obligations to the contracting process to ensure that legal obligations are imposed on the supplier.
Currently Croud does not perform annual assessments of our supply chain after onboarding of a new supplier. This is part of our roadmap for 2024 as Croud views this as a critical next step to our current practices.
As an office based service company, Croud acknowledges that the highest risk within the supply chain will be our office suppliers; third parties, as an example, who may be more prone to hire casual labour, industries with lower pay, smaller local companies.
We use Croud’s due diligence processes, supplier contracting and onboarding processes, risk assessment and management as well as awareness training to be able to identify any potential risk.
Whilst Croud sets its modern slavery risk level at low, Croud acknowledges that new risks or current practices may be identified or raised and that all employees should have an understanding of modern slavery. As such, Croud trains its employees annually on what modern slavery is, how to recognise it and how to raise and escalate any concerns. The training, which includes reading of Croud’s modern slavery policy, are also mandatory within the first week of an employee or contractor joining the business.
Croud’s policy, in conjunction with the training, ensures that every employee takes an active role and active responsibility in our plight to ensure that modern slavery does not enter our supply chain.
Croud is committed to eradicating modern slavery and has implemented a number of practises and processes to support maintaining that commitment. We will act promptly on any suspected breaches of policy or compliance that are identified to us. We continue to further improve and refine our approach on an annual basis.
Name: Richard Holmes
Title: CFO