Our Policies

Anti-Slavery & Human Trafficking Policy Statement

Anti-Slavery & Human Trafficking Policy Statement

This statement outlines the Anti-Slavery and Human Trafficking Policy of The Learning Web, a project owned by the Stand Together Network. Our policy demonstrates our commitment to preventing modern slavery and human trafficking within our operations and supply chains.

1. Introduction

1.1 This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes The Learning Web’s slavery and human trafficking statement for the financial year ending 31 July 2017.

1.2 The Learning Web is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or any part of its services. This statement outlines the preventive steps we are taking to mitigate the risk of modern slavery occurring within our services. 

2. Due Diligence Processes

2.1 To identify and mitigate the risks of modern slavery within our operations, The Learning Web adopts proportionate due diligence processes based on identified risk areas. These processes are subject to ongoing assessment and review.

2.2 We have systems in place to:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking in our supply chains.
  • Protect whistleblowers.

2.3 Key risk areas identified include:

  • Supply chains for goods and services, particularly IT equipment and uniforms.
  • Outsourced cleaning and security services.
  • Recruitment agencies for temporary staff.

3. Supply Chains

3.1 The Learning Web has identified the following business areas as carrying material risks of modern slavery: 

  • IT equipment
  • Clothing and uniforms
  • Outsourced cleaning services
  • Outsourced security services 

3.2 When tendering goods or services, we require potential suppliers to demonstrate high levels of corporate social responsibility and compliance with the Modern Slavery Act 2015. 

3.3 Suppliers identified in high-risk categories must provide evidence of compliance with the Modern Slavery Act 2015 and our own policies. 

3.4 Suppliers that fail to comply with the Modern Slavery Act 2015 or our policies will be removed from our list of approved suppliers. 

3.5 We will review the feasibility of introducing additional due diligence processes for monitoring and managing identified risks, including those associated with specific countries and products. 

4. Training

4.1 We provide training to staff responsible for recruitment, procurement, and contract management to ensure understanding of the risks of modern slavery and human trafficking. We also require our business partners to provide similar training to their staff and suppliers.

5. Recruitment Practices

5.1 Temporary staff and indirectly recruited staff are sourced through reputable recruitment agencies. We conduct checks on these agencies before approval. 

5.2 Our recruitment processes ensure that all approved agencies conduct relevant pre-recruitment checks and provide evidence of such checks. 

6. Company Policies

6.1 The Learning Web implements the following policies to embed good practice and provide remedies for potential instances of modern slavery: 

  • Grievance and Whistleblowing Policies: Allow employees, students, and others to raise concerns, including potential slavery risks, without fear of retaliation.
  • Employee Code of Conduct: Sets out expected actions and behaviour for employees.
  • Anti-Bribery and Corruption Policy: Maintains high standards of ethical conduct and integrity.
  • Procurement Policy: Reflects our commitment to ethical business relationships and effective safeguards.
  • Recruitment Policy: Ensures transparent recruitment processes and compliance with statutory requirements. 

7. Performance Indicators

7.1 Where risks of modern slavery are identified, we will introduce performance indicators (KPIs) to measure progress in reducing such risks. This may include: 

  • Use of grievance and whistleblowing procedures to raise concerns.
  • Assessment of third-party suppliers and their supply chains. 

7.2 This statement will be made available to all staff, stakeholders, and the public. We will raise awareness of modern slavery risks among staff, including discussing this statement during new employee inductions. 

7.3 We will assess training needs for all staff and develop relevant training programs in cooperation with external specialists. 

Document Review Plans

This document is subject to an annual review and will be updated as necessary in accordance with business requirements and changes.Â