Anti Slavery & Human Trafficking Policy
Anti-Slavery and Human Trafficking Policy
Last updated – July 2025
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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.Shape
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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Document Approval
Managing Director: _________________________ Date: _____________
Operations Director: _________________________ Date: _____________
Next Review: July 2026
