Slavery and Human Trafficking Statement. Financial Year: 1 April 2022 – 31 March 2023
Modern slavery is a crime and 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. The Modern Slavery Act 2015 introduced changes in UK law focused on increasing transparency in supply chains. Specifically, large businesses are required to disclose the steps they have taken to ensure their business and supply chains are free from modern slavery. Academic Action recognises that it has a responsibility to take a robust approach to slavery and human trafficking. This statement sets out the steps we have taken and continue to take to ensure that slavery and human trafficking are not taking place in any of our supply chains or businesses and is made pursuant to section 54(1) of the Modern Slavery Act 2015.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
Academic Action has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships to implement and enforce appropriate and effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in our supply chains.
We currently operate the following policies that ensure employees are aware of what is and is not acceptable practice and to allow them to raise concerns where appropriate:
Whistleblowing policy: We encourages all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains 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 repercussion.
Employee code of conduct: Our code of conduct makes clear to employees the actions and behaviour expected of them when representing Academic Action. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
OUR SUPPLY CHAINS
Academic Action does not have complicated supply chains with many levels, or suppliers with numerous sub contractors, however we do work with a wide range of suppliers and partners, some of which supply both temporary and permanent staff.
DUE DILIGENCE PROCESS FOR SLAVERY AND HUMAN TRAFFICKING
- Academic Action undertakes due diligence prior to appointing new suppliers and regularly reviews its existing suppliers. Our due diligence exercise involves accepting standard terms and conditions of trading to comply with all applicable anti-slavery and human trafficking laws.
- Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
- Ensuring our staff are vigilant to the potential threat of slavery and human trafficking
- To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, we require our staff to be familiar with our Anti-slavery and Human Trafficking Policy and we provide periodic reminders to our staff as well as the opportunity to undertake annual learning on the subject.
OUR EFFECTIVENESS AT COMBATING SLAVERY AND HUMAN TRAFFICKING
We have not identified any instances or indications that either slavery or human trafficking occurs in our business. As such, we have not considered it necessary to adopt any formal key performance indicated (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking does not take place in any part of our business or supply chains. We will continue to monitor and review these areas.
Academic Action is absolutely committed to preventing slavery and human trafficking in its corporate activities.