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Additional Information

Modern Slavery Act

Modern Slavery Act 2015 Policy Statement


Slavery and human trafficking (“Modern Slavery”) is a worldwide and far reaching issue. Clays is completely opposed to any form of slavery and human trafficking. Our staff are expected to highlight concerns that they may have, using the appropriate reporting channels, and management are expected to act accordingly.

This statement refers to the financial year ending 31st December 2022.

Our business

Clays is the UK’s market-leading book production specialist and the supplier to many leading publishing houses.  We specialise in producing monochrome paperbacks and hardbacks in any quantity and to a wide range of sizes. We have the capability to wire-stitch and perfect bind book blocks, finishing the product off with an extensive range of cover and jacket print and finishes.  Clays in based in Bungay, UK. 

Clays was acquired by Elcograf S.p.A (a member of the Italian Gruppo Pozzoni) in May 2018.

Our supply chains

Clays has been producing books for over 200 years and therefore has a mature, well-established supply chain for most products.  The majority of products and services are sourced from suppliers based in Europe.

Our supply chain due diligence processes

As part of our initiative to identify and mitigate risk, we have reinforced the systems in place to:

  • Identify and monitor risk areas in our supply chain
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains
  • Protect whistle blowers

These systems have been strengthened by:

  • Enhancement of our strategic supplier relationships, using where advantageous, our Group supply chain knowledge and experience.
  • The development of our sustainability agenda with a company commitment under SBTi has reinforced the links with our suppliers. Through more in-depth discussions with our key supply chain partners, we are able to more fully understand the extended supply chain and mitigate risks therein.
  • Supplier audits being carried out on key suppliers to Clays. Whilst we were unable to conducts as many visits to suppliers during 2020-2021 as previously, virtual meetings were held throughout the pandemic.  Going forward a revised audit programme is now in place.
  • Updating the General Terms of Purchase to state that suppliers are required to adhere to the Clays Ethical Trading Policy.

Going forward:

  • Clays is committed to enhancing our supply chain interactions further through a strategic re-evaluation process to identify any changing risks or additional areas to focus.
  • We will also develop the training provided to a wider group of stakeholders within the business to improve awareness.

Our policies

Clays will not knowingly do business with any organisation or body involved in slavery or human trafficking. Our commitment to the Modern Slavery Act 2015 is reinforced by the following policies:

  • Ethical Trading Policy
  • Whistleblowing Policy
  • Grievance Procedure
  • Receipt of Gifts

Our People

Our HR function addresses employee issues and conducts a formal recruitment process which includes pre-employment checks. This includes processes to ensure that employees have the right to work in the United Kingdom and Clays complies with the National Living Wage which became law on 1 April 2016.

Staff awareness initiatives are conducted within Clays facilitated by training for specific roles. The HR policies are reviewed periodically and rolled out to all employees.

This policy statement concerning slavery and human trafficking is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by Clays Board on 24th April 2023.



Edoardo Cuomo

CEO, Clays

April 2023