Modern Slavery and Human Trafficking statement

Educate Resourcing considers the obligations placed on commercial organisations under section 54(1) of the Modern Slavery Act 2015 are vital in combating modern slavery and human trafficking.

This statement sets out our current practice and constitutes compliance statement.

Purpose

This statement sets out Educate resourcing’s actions to understand potential modern slavery risks related to its business and put in place steps aimed at ensuring there is no slavery or human trafficking, forced labour or exploitation in its own business or its supply chain

Organisational structure and supply chains

This statement covers the business activities of Educate Resourcing. It covers direct employees of Educate Resourcing, agency workers engaged through Educate resourcing and the relationship with Schools and local Authorities.

Regions of operation and supply

Educate Resourcing operates in the United Kingdom. Whilst the risk of slavery and human trafficking is considered low, Educate Resourcing remains vigilant and will take all steps available to manage the risks presented.

High-risk activities

Educate Resourcing has determined there are no areas of its business considered at high risk of slavery or human trafficking:

Responsibility

Responsibility for Educate Resourcing anti-slavery initiatives is as follows;

Policies: The Directors will ensure appropriate recruitment and employment policies are in place and reviewed annually.

Risk assessments: Are undertaken by the relevant service area where there is deemed a risk of modern slavery or human trafficking, with the support of colleagues in HR and Finance. The risk assessment will be signed by the appropriate director and held centrally and demonstrate the corporate responsibility for human rights and modern slavery risk analysis.

Investigations/due diligence: Any concerns regarding modern slavery or human trafficking will be raised with the Directors in the first instance.

Training: Awareness of the issue of human trafficking and modern slavery forms part of the Educate Resourcing Induction and is reviewed annually.

Relevant policies

Educate Resourcing operates the following policies which are being reviewed and updated to set out our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our services and operations:

Whistleblowing policy – The organisation encourages all workers, customers and other business partners to report any concerns related to the direct activities of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Employee code of conduct: Educate Resourcing Ltd code makes it clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour in all its operations and when managing all aspects of the business.

Expectations of Suppliers: Educate Resourcing is committed to ensuring its suppliers adhere to the highest ethical standards. Suppliers are required to demonstrate they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure they meet the required standards. However, serious violations of Educate Resourcing’s supplier expectations will lead to termination of the business relationship.

Practical guidance

Modern Slavery

Modern slavery is the movement and trade of people of any age, often for the purpose of sexual exploitation, forced labour or organ harvesting. Modern slavery can include victims that have been brought from overseas, and vulnerable people in the UK.

Human traffickers can use a variety of means to recruit, transport, receive and hide their victims such as threats or force, abduction, deception or false promises.

Spot the signs

Signs of slavery are often hidden, making it even harder to recognise victims around us. Here are some common signs to be aware of:

Poor physical appearance

Victims may show signs of physical or psychological abuse, look malnourished or unkempt, or appear withdrawn and neglected. They may have untreated injuries.

Isolation

Victims may rarely be allowed to travel on their own, seem under the control, influence of others, rarely interact or appear unfamiliar with their neighbourhood or where they work.

Poor living conditions

Victims may be living in dirty, cramped or overcrowded accommodation, or living and working at the same address.

Few or no belongings

Victims may have no identification documents, have few personal possessions and always wear the same clothes day in day out.

Restricted freedom of movement

Victims may have little opportunity to move freely and may have had their travel documents retained, such as passports.

Unusual travel times

They may be dropped off or collected for work on a regular basis either very early or late at night.

Reluctance to seek help

Victims may avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their family.

They may be accompanied by someone else who speaks for them.

Grooming

Children may not always demonstrate outward signs of distress and may have a “bond” with those exploiting them and have been groomed to not disclose their abuse – however, they are likely to be very scared and traumatised.

Report it

If you believe a person is being trafficked and is in immediate danger, you should call 999 straight away.

Communities have an important role to play in recognising abuse. If you recognise any of the above signs and suspect someone may be a victim of modern slavery, tell someone. You will always be taken seriously and protection and support is available.

You can report suspected modern slavery:

Help and support

For further advice and support there are a number of agencies who can help
Modern Slavery Helpline website (08000 121 700) 

Due diligence

Educate Resourcing undertakes due diligence when considering new suppliers and regularly reviews its existing suppliers. This is the responsibility of individual procurement managers.

The organisation’s due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical
  • risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier
  • conducting annual assessments of qualifying suppliers on financial stability, compliance with various employment policies and where risks are identified greater focus on slavery and human trafficking;
  • creating a risk profile for each qualifying supplier to cover all the above issues;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans for example to demonstrate compliance with safer recruitment requirements; participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
  • invoking sanctions against suppliers who fail to improve their performance in line with an action plan or who seriously violate our expectations of suppliers, including the termination of the business relationship
  • All invitations to tender for business with Educate Resourcing will include the following statement:
    • “We are committed to ensuring there is no modern slavery or human trafficking in our supply chains. Educate Resourcing will not support or deal with any business knowingly involved in slavery or human trafficking.

Training

Educate Resourcing requires all staff responsible for supply chain management to complete training on modern slavery. We are reviewing existing training material to determine its effectiveness in light of the Modern Slavery Act 2015.

The modern slavery training will cover:

  • our business purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within Educate Resourcing
  • what external help is available, for example through the Modern Slavery Helpline, Gang-masters and Labour Abuse Authority and “Stronger together” initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • the steps we take if suppliers or contractors do not implement antislavery policies in high-risk scenarios, including their removal from the organisation supply chains.