Anti-Slavery and Human Trafficking Policy

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This policy in 60 seconds

• Who it is for: TTT staff, associates, resellers and suppliers.
• TTT has zero tolerance of modern slavery, trafficking and forced labour across its work and supply chain.
• Immediate danger: call 999. Advice line: Modern Slavery and Exploitation Helpline 08000 121 700 (24 hours).
• Report concerns to phenil@theteachertrainer.co.uk or 01908 736 777. We acknowledge within 3 working days and investigate, typically within 28 calendar days.

The full policy below is the official version.

1. Purpose

This policy sets out TTT's zero-tolerance position on modern slavery, human trafficking, servitude and forced or compulsory labour across its operations, workforce and supply chain. It demonstrates TTT's commitment to ethical practice in line with the Modern Slavery Act 2015, even though TTT's turnover sits below the statutory threshold for a Modern Slavery Statement. TTT chooses to hold itself to the same standard expected of larger organisations, because learners, Awarding Organisations and the sector deserve that assurance.

2. Scope

This policy applies to:

• All TTT employees, associates, contractors, volunteers and directors
• All TTT resellers, suppliers and significant commercial partners
• TTT learners, where they raise concerns about modern slavery affecting themselves or others
• All TTT operations, including online delivery, administrative services and physical premises

3. Definitions

The following terms carry the meanings given in the Modern Slavery Act 2015 and associated statutory guidance.

4. Policy Statement

TTT is committed to the following principles and commitments.

1. 1TTT has a zero-tolerance approach to modern slavery and human trafficking in every part of its activity and supply chain.
2. 2TTT complies with the Modern Slavery Act 2015 and, although not currently required to publish a statutory Modern Slavery Statement, voluntarily applies the statement's principles.
3. 3Every person working for TTT is engaged lawfully, has confirmed right to work, holds their own identity documents and is paid in line with the National Minimum Wage and National Living Wage rates set by the UK Government.
4. 4TTT conducts risk-based due diligence on new resellers, suppliers and significant contractors, proportionate to size and risk exposure.
5. 5Contracts with resellers and significant suppliers include anti-slavery clauses giving TTT the right to audit and to terminate for material breach.
6. 6Every staff member and associate is made aware of this policy and knows how to recognise and report concerns.
7. 7Concerns raised in good faith are handled promptly, confidentially and without detriment to the person raising them, consistent with the Whistleblowing Policy.
8. 8Where TTT encounters credible evidence of modern slavery, it reports to the relevant authority (Modern Slavery Helpline, Police, National Referral Mechanism) without delay.

5. Roles and Responsibilities

6. TTT's Risk Profile

TTT delivers online vocational training in the UK. Its operational risk of direct involvement in modern slavery is low, but not zero. The following areas carry the most exposure and are monitored accordingly.

7. Indicators of Modern Slavery

Every staff member and associate is trained to recognise the following indicators. Indicators are not proof, but any combination warrants further care and, where credible, a referral to the authorities.

• A third party speaks for the individual, handles their identity documents or controls their access to money
• The same contact details or bank account are used for multiple unrelated learners
• The individual appears anxious, withdrawn, rehearsed or inconsistent in their account of themselves
• Signs of physical injury, under-nourishment or inappropriate clothing
• The individual has limited or no personal identification or is reluctant to discuss where they live
• The individual appears to be moved by others between locations and is reluctant to travel alone
• Payment for an enrolment is made by a third party who also controls course choice and contact
• A supplier's pricing is implausibly low relative to the market, with weak or unverifiable labour practices
• Workers at a supplier site are reported to live in the workplace, lack freedom of movement or have no contract

8. Internal Controls

8.1 Workforce

• Every staff member, associate, contractor and volunteer is recruited under the Safer Recruitment Policy, including Right to Work verification and identity checks
• Each individual holds their own identity documents and controls their own bank account into which they are paid
• Payment is at or above the National Minimum Wage or National Living Wage as applicable or at proper professional rates for associate services
• Working hours are reasonable and recorded; no individual is required or encouraged to work under duress

8.2 Supply chain and resellers

• Before engagement, new resellers and significant suppliers are asked to confirm their anti-slavery position, typically by signing or acknowledging TTT's anti-slavery clause
• Contracts include a right to audit and a right to terminate for material breach
• Large suppliers who publish a Modern Slavery Statement under Section 54 of the Modern Slavery Act 2015 are preferred; their statement is checked at onboarding and annually
• Where a supplier cannot or will not meet these expectations and the service cannot be secured elsewhere, TTT records the residual risk and the steps taken to mitigate it

8.3 Learner-facing

• At enrolment, TTT verifies identity, confirms direct contact and ensures that the learner makes their own decision about the course
• Where a sponsor or employer pays on a learner's behalf, TTT retains the direct relationship with the learner, including for course-delivery communication, under the Reseller Agreement and the Course Terms and Conditions
• Course Tutors, Assessors and IQAs who observe anything that suggests a learner is being coerced, controlled or isolated route the concern to the Designated Safeguarding Lead (Phenil Mehta) without delay under the Safeguarding and Prevent Duty Policy

9. Reporting Concerns

Any staff member, associate, learner or third party with a concern about modern slavery or human trafficking affecting any person connected to TTT reports it through one of the following routes.

9.1 Immediate danger

• If a person is in immediate danger: call 999 (Police and ambulance)
• Modern Slavery and Exploitation Helpline: 08000 121 700 (24 hours) for urgent advice and referral

9.2 Internal reporting

• Concerns are reported to the Centre Manager at phenil@theteachertrainer.co.uk or 01908 736 777
• Where the concern involves the Centre Manager or the Centre Manager is otherwise conflicted, concerns are reported to the Alternative Contact (Shaily Mehta, shaily@theteachertrainer.co.uk)
• Any staff member can raise a concern anonymously or confidentially through the Whistleblowing Policy, which provides protection under the Public Interest Disclosure Act 1998

9.3 External reporting

• Modern Slavery and Exploitation Helpline (Unseen UK): 08000 121 700 or modernslaveryhelpline.org
• Police: 101 for non-urgent reports, 999 for emergencies
• National Crime Agency (NCA) Modern Slavery Human Trafficking Unit: via nationalcrimeagency.gov.uk
• Gangmasters and Labour Abuse Authority (GLAA): 0800 432 0804
• National Referral Mechanism (NRM): the statutory framework for identifying and supporting potential victims, accessed through first-responder organisations
• Crimestoppers (anonymous): 0800 555 111

10. How TTT Handles a Concern

1. 1The concern is acknowledged in writing within 3 working days of receipt (where contact details are provided).
2. 2The Centre Manager (or Alternative Contact) assesses the information and takes immediate action to protect any person at risk, including contacting authorities where appropriate.
3. 3Where a learner may be a victim, safeguarding steps under the Safeguarding and Prevent Duty Policy are activated in parallel.
4. 4A proportionate investigation is carried out, typically within 28 calendar days, with external expertise engaged where the matter is complex.
5. 5An outcome is communicated to the person raising the concern (subject to lawful restrictions), with action taken and next steps set out.
6. 6Lessons are fed back into the policy, supplier list and staff training.

11. Protection from Detriment

• No staff member, associate, contractor, volunteer, learner or third party will suffer detriment for raising a concern in good faith
• Retaliation against a person raising a concern is a serious breach of the Staff Code of Conduct and is handled under the Staff Disciplinary and Sanctions Policy
• Protection extends to victims themselves; TTT supports potential victims through the National Referral Mechanism and does not take immigration or commercial action that would penalise a victim

12. Breach of This Policy

Breach of this policy is treated with the utmost seriousness.

• Staff and associates face action under the Staff Disciplinary and Sanctions Policy, up to and including dismissal and referral to the Disclosure and Barring Service, the Police and any relevant professional register
• Resellers face suspension or termination under the Reseller Agreement, alongside referral to authorities where criminal conduct is suspected
• Suppliers who do not uphold equivalent anti-slavery standards and who cannot demonstrate progress, are removed from TTT's approved list

13. Training and Awareness

14. Records and Retention

• Signed supplier anti-slavery acknowledgements are held in the supplier register for the life of the engagement plus 6 years
• Concerns raised, investigations and outcomes are retained for 6 years after case closure or longer where the Awarding Organisation or law requires
• Personal data is processed under the Data Protection and GDPR Policy; victim-related information is held with heightened confidentiality

15. Voluntary Transparency

Although TTT is below the Section 54 Modern Slavery Act threshold that requires publication of an annual Modern Slavery Statement, TTT chooses to:

• Publish this policy openly on its website
• Include anti-slavery expectations in reseller and significant supplier contracts
• Review and summarise its anti-slavery activity annually in its internal self-evaluation
• Publish a short voluntary statement summarising its position should the scale of TTT's operations change such that publication would add value to learners, partners and the sector

16. Monitoring and Review

This policy is reviewed annually by the Centre Manager as part of TTT's self-evaluation process. Interim reviews are triggered by legal or statutory guidance changes, significant incidents, a change in TTT's size or international activity or identified weaknesses in the supply chain. All outcomes are recorded in the Version History at Section 18.

17. Related Policies

This policy should be read alongside:

18. Version History

19. Approval

This policy has been reviewed and approved by the Centre Manager of TTT.