Modern Slavery Statement

1The policies behind this statement

Our policies reflect a commitment to acting ethically and with integrity in everything we do.

• Speak Up Policy, so anyone can report unethical practice confidentially
• Equality, Diversity & Inclusion Policy, promoting fairness, equity and respect
• Data Protection & GDPR Policy, for secure and lawful handling of personal data
• Safeguarding & Prevent Policy, protecting vulnerable individuals and supporting conduct aligned with anti-exploitation principles
• PRO-020 Freelancer Vetting & Onboarding, so subcontractors and freelance trainers meet our ethical, legal and integrity requirements

2Risk management

We actively identify and mitigate the risk of modern slavery in our operations and supply chain.

Our supply chain is predominantly UK-based and low risk, but we stay vigilant for outsourced services such as digital platforms, IT services and subcontracted training providers. Risks are assessed using the principles in PRO-017 and recorded where relevant in FOR-016.

We work with suppliers to raise awareness of modern slavery and we build ethical considerations into procurement decisions. Every new supplier, contractor and training partner undergoes proportionate due diligence aligned with PRO-020, and we may ask for additional assurances where a supplier is assessed as medium or high risk.

3What we require of our supply chain

• Suppliers and contractors comply with the principles of the Modern Slavery Act 2015
• All supplier contracts include clauses requiring adherence to anti-slavery law and practice
• Any non-compliance reported through our Speak Up Policy is investigated promptly and thoroughly
• Suppliers notify us of any subcontractor engaged in delivering services, so the supply chain stays transparent
• Contracts may be terminated where a breach of this statement is identified
• Freelance trainers and partner organisations maintain ethical practice aligned with PRO-020 and the Supplier Code of Conduct

4Awareness and training

Awareness is central to prevention.

• Employees are trained to recognise the signs of modern slavery and to understand the reporting routes, aligned with the IMS training matrix and refreshed periodically
• Guidance materials and workshops reinforce awareness
• Clear, confidential mechanisms are in place for staff to report concerns
• Reports can go to the Head of Centre, the Quality Manager, or through the Speak Up Policy, which allows anonymous disclosure
• Freelancers and contractors complete awareness training proportionate to their role

5Monitoring effectiveness

We monitor how well we are preventing modern slavery through the IMS: supplier checks, staff training and ongoing review of procurement decisions.

Our anti-slavery measures are evaluated annually as part of the IMS Management Review (PRO-007), which assesses effectiveness, risks and opportunities to improve. We engage with employees, suppliers and partners to gather insight, and we document and address any concern or violation reported within our operations or supply chain.

6Governance and accountability

The Head of Centre holds primary accountability for compliance with modern slavery legislation and for implementing this statement. The Senior Leadership Team provides strategic oversight and makes sure the resources are there to maintain compliance.

The Quality Manager monitors supplier compliance, training completion and due diligence, maintains the records in FOR-016, and supports investigations and corrective action.

The Senior Leadership Team oversees the implementation of anti-slavery measures, ensures compliance with relevant law and ethical standards, and reviews and updates this statement annually as part of the IMS Management Review.

7Reporting and transparency

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015. It is reviewed and updated annually to reflect our ongoing commitment to tackling modern slavery and human trafficking.

It is published on our website and made available to interested parties on request.

As at the most recent review, no incident of modern slavery has been identified within Acadame or its supply chain.