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Modern slavery is a serious crime that constitutes a violation of fundamental human

rights. In accordance with the Modern Slavery Act 2015 (the Act), this policy

addresses the offences of slavery, servitude, forced or compulsory labour, and

human trafficking, ensuring that our organisation remains committed to preventing

any form of modern slavery within our business or supply chains.

Definitions of Modern Slavery

 Slavery: Defined by the 1926 Slavery Convention, it refers to a condition in

which one person exercises powers of ownership over another, depriving

them of their freedom.

 Servitude: Involves a person being forced to provide services through

coercion, without the ability to change their circumstances.

 Forced or Compulsory Labour: As defined by the International Labour

Organisation (ILO), this occurs when work is imposed under threat or coercion

and the individual has not voluntarily agreed to it.

 Human Trafficking: Refers to the arrangement or facilitation of travel for an

individual with the intent to exploit them, regardless of whether they consent

to travel.

 Child Labour: Refers to the exploitation of children under the age of 12 in

economic activities or those aged 12-14 in more than light work, and any child

engaged in the worst forms of child labour.

The Policy

We are committed to combating all forms of modern slavery and ensuring that our

operations and supply chains remain free from such exploitation. This policy applies

to all staff and suppliers we work with.

Compliance Requirements

Under the Modern Slavery Act, commercial organisations in the UK with an annual

turnover above £36 million are required to produce a slavery and human trafficking

statement each financial year. This statement must outline steps taken to prevent

modern slavery within their supply chains. Although our organisation does not meet

the £36 million threshold, we remain committed to transparency and good practice in

addressing modern slavery risks, voluntarily producing a modern slavery statement

to share with partners, suppliers, and commissioners.

Smaller Organisations

Smaller organisations, including ours, are encouraged to take proportionate steps to

address modern slavery risks. We will continue to monitor our suppliers and engage

in practices consistent with the Act’s guidance, including promoting transparency and

due diligence in our recruitment and supply chain processes.

Reporting

All staff have a duty to report any concerns or suspicions about potential modern

slavery to their line manager. In turn, the manager will take appropriate action,

including reporting to the Modern Slavery Helpline (08000 121 700) or via the online

platform: Modern Slavery Helpline.

Related Policies

 Adult Safeguarding

 Confidentiality

 Data Protection (GDPR)

 Recruitment and Selection

 Safeguarding Children

 Whistleblowing

Related Guidance

Gov.UK: https://www.gov.uk/government/collections/modern-slavery

Transparency in Supply Chains: A Practical Guide:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/64990

6/Transparency_in_Supply_Chains_A_Practical_Guide_2017.pdf

Modern Slavery Helpline: https://www.modernslaveryhelpline.org/report

Gov. UK A Call to Action to End Forced Labour, Modern Slavery and Human

Trafficking: https://www.gov.uk/government/publications/a-call-to-action-to-end-

forced-labour-modern-slavery-and-human-trafficking

Training Statement

All staff will be provided with training on the Modern Slavery Act and our

organisation’s policies as part of their induction. Ongoing training will be available to

ensure that staff and managers are aware of their responsibilities and are equipped

to identify and report modern slavery concerns.

Approval

This statement was approved by:

Name: Sandra Mononga

Date: Feb 2025

This policy reflects our commitment to ethical business practices, human rights, and

the prevention of modern slavery in all areas of our operations.