Anti Slavery & Human Trafficking Policy

Anti-Slavery and Human Trafficking Policy

Last updated – July 2025

This policy establishes our unwavering commitment to combating slavery and human trafficking in all forms within our education recruitment services and supply chains. We recognise that the education sector requires absolute vigilance in protecting vulnerable individuals, particularly children and young people, from exploitation and abuse. Our commitment extends beyond legal compliance to encompass ethical leadership in safeguarding human rights and dignity.

Our anti-slavery obligations apply to all temporary agency workers, permanent staff, contractors, suppliers, and third parties working on behalf of our agency in connection with our services to educational organisations and the broader community we serve.

Scope and Application

Covered Activities

This policy applies to all aspects of our business operations including:

Recruitment and Employment:

• Direct employment practices and candidate screening procedures
• Temporary staffing arrangements and agency worker placements
• Contractor and subcontractor engagement processes
• Volunteer recruitment and management within educational settings
• International recruitment and visa sponsorship arrangements

Supply Chain Management:

• Procurement of goods and services from third-party suppliers
• Due diligence on suppliers, contractors, and business partners
• Monitoring of supply chain labour practices and working conditions
• Evaluation of supplier locations and operational jurisdictions
• Assessment of high-risk sectors and geographical areas

Educational Environment Protection:

• Safeguarding vulnerable individuals within school communities
• Monitoring for indicators of exploitation among pupils and families
• Training staff to recognise signs of modern slavery and trafficking
• Integration with existing safeguarding and child protection frameworks
• Community outreach and awareness programs

Legal Framework Compliance

Modern Slavery Act 2015:

• Annual transparency statement publication and board approval
• Due diligence procedures across all business relationships
• Risk assessment methodologies for identifying potential slavery
• Remediation processes for addressing identified violations

Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015:

• Compliance with transparency reporting requirements
• Victim identification and support procedures
• Law enforcement cooperation protocols
• Training requirements for staff and management

Education Specific Considerations:

• Integration with Keeping Children Safe in Education 2025 requirements
• Alignment with Leeds Safeguarding Children Partnership protocols
• Cooperation with Multi-Agency Safeguarding Hub (MASH) procedures
• Compliance with Prevent Duty guidance and radicalisation prevention

Risk Assessment and Management

High Risk Indicators

Organisational Risk Factors:

• Complex supply chains with multiple tiers of subcontracting
• Operations in or sourcing from high-risk geographical regions
• Use of labour providers and employment agencies
• Seasonal or temporary staffing requirements

Individual Risk Indicators:

• Workers showing signs of physical or psychological abuse
• Individuals with restricted freedom of movement or communication
• Evidence of debt bondage or excessive recruitment fees
• Workers living in substandard or controlled accommodation
• Sector-Specific Vulnerabilities

Education Environment Risks:

• Vulnerable pupils from disadvantaged or unstable backgrounds
• International students and exchange program participants
• Families with unclear immigration status or documentation
• Isolated school communities with limited external oversight

Supply Chain Vulnerabilities:

• Cleaning and maintenance service contractors
• Catering and food supply arrangements
• Construction and facilities management services
• IT equipment and technology suppliers

Due Diligence Procedures

Pre-Engagement Assessment:

• Comprehensive screening of all potential business partners
• Financial stability and operational transparency evaluations
• Site visits and workplace condition assessments where appropriate
• Reference checks with previous clients and regulatory bodies

Contractual Safeguards:

• Mandatory anti-slavery clauses in all supplier and contractor agreements
• Right to audit and inspect facilities and employment practices
• Immediate termination rights for slavery-related violations
• Requirement for suppliers to extend obligations through their supply chains

Ongoing Monitoring:

• Regular review of supplier performance and compliance status
• Spot checks and unannounced audits of high-risk arrangements
• Worker feedback mechanisms and anonymous reporting channels
• Integration of anti-slavery metrics into procurement decisions

Employment Practices

Recruitment Standards:

• Prohibition of recruitment fees charged to workers
• Transparent employment terms and conditions in appropriate languages
• Verification of right to work documentation through approved methods
• Fair and equitable treatment regardless of nationality or immigration status

Working Conditions:

• Compliance with minimum wage legislation and working time regulations
• Provision of appropriate breaks, holidays, and workplace facilities
• Respect for workers' freedom of association and collective bargaining rights
• Safe and healthy working environments meeting regulatory standards

Training and Awareness

Staff Development Program

Induction Training:

• Comprehensive modern slavery awareness for all new employees
• Specific indicators relevant to education sector environments
• Practical guidance on reporting procedures and escalation protocols
• Cultural sensitivity training for working with diverse communities

Specialised Training:

• Enhanced training for procurement and HR staff on supply chain risks
• Safeguarding-focused sessions for staff working directly with pupils
• Leadership training for managers on policy implementation and oversight
• Regular updates on emerging trends and legislative development

Community Engagement

Educational Institution Partnership:

• Joint training sessions with school leadership teams
• Development of awareness materials for educational settings
• Support for schools in developing their own anti-slavery policies
• Integration with broader safeguarding and welfare programs

Public Awareness Initiatives:

• Community presentations on modern slavery recognition and reporting
• Partnership with local authorities and law enforcement agencies
• Support for awareness campaigns during Anti-Slavery Day activities
• Collaboration with specialist charities and support organisations

Reporting and Response Procedures

Incident Identification

Internal Reporting Mechanisms:

• Multiple confidential reporting channels including anonymous options
• Clear escalation procedures for different types and severity of concerns
• Protection for whistleblowers against retaliation or discrimination
• Regular communication about the importance and process of reporting

External Reporting Obligations:

• Immediate notification to law enforcement agencies for criminal matters
• Cooperation with National Crime Agency and local police investigations
• Reporting to relevant regulatory bodies and professional organizations
• Coordination with local authority safeguarding teams where appropriate

Response and Investigation

Immediate Actions:

• Suspension of business relationships pending investigation where appropriate
• Implementation of interim measures to protect potential victims
• Preservation of evidence and documentation relevant to allegations
• Coordination with law enforcement and statutory agencies

Formal Investigation Process:

• Independent investigation conducted by appropriately trained personnel
• Cooperation with external agencies and provision of necessary information
• Assessment of systemic issues and implementation of corrective measures
• Regular review and monitoring of remedial actions effectiveness

Victim Support and Remediation

Victim Identification and Support

Recognition Procedures:

• Training for staff to identify potential victims of modern slavery
• Established protocols for initial contact and assessment
• Coordination with specialist support services and charities
• Integration with existing safeguarding and child protection procedures

Support Services:

• Access to appropriate medical, psychological, and legal support
• Coordination with statutory agencies for ongoing protection and care
• Assistance with accommodation, documentation, and integration services
• Long-term support planning in partnership with specialist organisations

Remediation Measures

Immediate Remediation:

• Termination of business relationships with non-compliant partners
• Implementation of enhanced monitoring and oversight procedures
• Financial compensation or support for affected individuals where appropriate
• Public disclosure of remedial actions taken and lessons learned

Systemic Improvements:

• Review and strengthening of policies, procedures, and controls
• Enhanced training and awareness programs across the organisation
• Improved due diligence and monitoring systems
• Regular assessment of policy effectiveness and continuous improvement

Supply Chain Management

Pre-Qualification Requirements:

• Mandatory completion of anti-slavery questionnaires and declarations
• Evidence of appropriate policies, procedures, and training programs
• Financial and operational transparency including subcontracting arrangements
• Demonstration of compliance with relevant legislation and standards

Risk-Based Categorisation:

• Enhanced due diligence for high-risk suppliers and arrangements
• Regular re-assessment and updating of risk classifications
• Tailored monitoring and oversight based on identified risk levels

Contract Management

Standard Contract Terms:

• Comprehensive anti-slavery and human trafficking clauses
• Requirements for suppliers to implement equivalent policies and procedures
• Audit rights and inspection procedures with appropriate notice periods
• Clear consequences for non-compliance including contract termination

Performance Monitoring:

• Regular review meetings incorporating anti-slavery compliance discussions
• Key performance indicators including slavery-related metrics
• Incident reporting and investigation procedures
• Continuous improvement requirements and implementation monitoring

Internal Communication

• Regular updates to staff on policy developments and performance
• Integration of anti-slavery messaging into broader organisational communications
• Recognition and celebration of positive contributions and achievements
• Clear guidance on roles, responsibilities, and expectations

Related Policies and Procedures

• Safeguarding Policy and Procedures
• Recruitment and Selection Policy
• Procurement Policy and Supplier Code of Conduct
• Whistleblowing Policy and Procedures
• Data Protection Policy and Procedures
• Health and Safety Policy
• Equality, Diversity and Inclusion Policy

APPENDICES

Appendix A: Modern Slavery Risk Assessment Template

Appendix B: Supplier Anti-Slavery Questionnaire

Appendix C: Incident Reporting Form and Procedures

Appendix D: Training Record Template and Requirements

Appendix E: Contact Directory for Anti-Slavery Matters

Appendix F: Annual Statement Template and Guidance

Appendix G: Victim Support Resource Directory

Next Review: July 2026