Modern Slavery Policy
Modern slavery is a crime and a violation of fundamental human rights. It can take various forms such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or through our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes and learner placements, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether they be adults or children, and we expect our suppliers to hold their suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, apprentices, contractors, external consultants, third-party representatives, board members and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
The Chief Executive Officer has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
Day to day the Chief Executive Officer has primary responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
All managers are responsible for ensuring those reporting to them understand and comply with this policy.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Chief Executive Officer.
All employees must ensure that they have read, understood and comply with this policy. The prevention, detection and reporting modern slavery in any part of our business or throughout supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to or suggest a breach of this policy. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at any tier at the earliest possible stage. If you believe or suspect that a breach of this policy has occurred or may occur, you must notify your manager or report it in accordance with the whistleblowing section of the Malpractice and Maladministration Policy as soon as possible. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Chief Executive Officer.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result in reporting in good faith their suspicion that modern slavery in any form is taking place in any part of our business operations and supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe you have suffered any such treatment, you should inform the Chief Executive Officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure.
This zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, apprentices and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Approved and signed by:
Paul Williams
Chief Executive
Reviewed 6th January 2025
(to be reviewed January 2026)
