Modern Slavery and Human Trafficking Policy

Effective Skills Training Ltd

Policy Statement

Effective Skills Training Ltd is unequivocally committed to preventing modern slavery and human trafficking in all its corporate activities, and to ensuring that its supply chains, including its network of associate trainers and suppliers, are free from slavery and human trafficking.

This policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our business or supply chains.

1. Introduction and Purpose

Modern slavery is a crime and a gross violation of fundamental human rights. It takes 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 in order to exploit them for personal or commercial gain.

Effective Skills Training Ltd has a zero-tolerance approach to modern slavery. The purpose of this policy is to:

• Set out our commitment to preventing, detecting, and reporting modern slavery in all its forms within our business and supply chains.

• Provide guidance to our employees, associates, and suppliers on how to recognise and report concerns.

• Comply with our legal and ethical obligations under the Modern Slavery Act 2015.

2. Scope of the Policy

This policy applies to all persons working for Effective Skills Training Ltd or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and our network of associate trainers and business partners.

3. Responsibilities

The Managing Director, John O’Sullivan, has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

All employees and associates have a responsibility to read, understand, and comply with this policy. They must avoid any activity that might lead to, or suggest, a breach of this policy. Everyone is encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains at the earliest possible stage.

4. Our Commitments and Due Diligence Processes

We are committed to acting ethically and with transparency in all our business dealings. Our due diligence processes include:

• Supply Chains and Associate Network: We operate a network of trusted associate trainers and suppliers. Our due diligence process for new and existing associates and suppliers includes:

  • Verifying that all associates are legitimate, qualified professionals who have the right to work in the UK.

  • Conducting background checks, including DBS checks where appropriate for the nature of the training delivered.

  • Communicating our policy and our expectation that they adhere to the same high standards and have their own robust procedures in place.

  • Evaluating the modern slavery and human trafficking risks of each new supplier.

• Recruitment and Employment: We conduct robust recruitment processes, including verifying the identity and right to work of all direct employees to prevent illegal working. We are committed to providing a fair and ethical workplace, ensuring all staff are paid at least the National Minimum Wage or National Living Wage as appropriate.

• Risk Assessment: We recognise that our primary risk lies within our supply chain and associate network. We will continue to assess and manage this risk by building long-standing relationships with our partners and making clear our expectations of business behaviour.

• Whistleblowing: We encourage all our workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

5. Training and Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide training to our staff and associates as necessary. We will also communicate our zero-tolerance approach to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforce it as appropriate thereafter.

6. Breaches of this Policy

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.

7. Policy Review

This policy will be reviewed by the Managing Director on an annual basis to ensure it remains relevant and effective.

Contact

For any questions or concerns relating to this policy, please contact:

John O’Sullivan Managing Director Effective Skills Training Ltd

Email: info@effectiveskillstraining.com

Phone: 03300433808 Website: www.effectiveskillstraining.com

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