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SLAVERY AND HUMAN  TRAFFICKING POLICY.

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Introduction

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes 1st2 Achieve Training (1ST2A) slavery and human trafficking statement for the academic year 2020-2021.
TSDC is committed to improving our practices to combat slavery and human trafficking.

Scope

We are a private training provider accessing a range of funding streams; including ESF, AEB, ESFA Direct Contracts, etc. We are based in the north-west of England, but operate nationally, delivering qualifications in Construction, Customer Service, Business Administration, Leadership and Management, both in our training centres and on-site at employer’s premises. To ensure effective delivery of our service office our supply chain includes Awarding Organisations, freelance consultants and resource suppliers.

We will make sure our suppliers are aware of our policies, and we expect our supply chain to adhere to the same high standards.
As part of our initiative to identify and mitigate risk: –

  • We expect our Supply Chain to have suitable anti-slavery and human trafficking polices and processes in place

  • We expect each entity in the supply chain to, at least, adopt ‘one up’ due diligence on the next link in the chain.

It is not practical for us (and every other participant in the chain) to have direct relationships with all links in the supply chain, but we are committed to: –

  • better understanding our supply chains and working towards greater transparency in, and responsibility towards, people working within them.

  • working with our suppliers in our supply chains to encourage more of them to commit to the highest standards of business in dealing with Modern Slavery

Our Senior Management Team (SMT) has overall responsibility for ensuring this policy complies with our legal and ethical obligations.

Risk and Compliance

We have produced an anti-slavery and human trafficking policy, which is published within our company employee handbook, to complement our existing policies regarding the human rights of workers.

We play an active role in supplier development and are in the process of adopting various means to clearly communicate our expectations to our suppliers.

We are reviewing the vetting process for our supply chain, and are working collaboratively with them, to endeavour to ensure they can meet their legal requirements under the Act.

We will endeavour to ensure all our suppliers adhere to our anti-slavery policy. For example, if we find evidence of a failure to comply with our policies we will immediately seek to terminate our relationship with the relevant supplier.

Effectiveness and KPIs

We have reviewed our key performance indicators (KPIs) relevant to the introduction of the Modern Slavery Act 2015.

As a result, we have set the following KPI:

  • All current staff/site personnel to have completed anti-slavery and human trafficking training within 3 months of their start date.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we provide training to relevant members of staff when applicable.

Monitoring and Review

The impact of this Policy will be monitored through rigorous performance reporting to management and the Director. This policy will be subject to a planned review every three years as part of the organisation’s policy review process. It is recognised however that there may be updates required in the interim arising from amendments or release of new regulations, codes of practise or statutory provisions or guidance from government bodies.

Responsibility for review: Thomas Cartwright, Director
Review Date: April 2021