Section 54 of the Modern Slavery Act 2015 –slavery and human trafficking statement
Introduction
This statement is made in accordance with section 54 of the Modern Slavery Act 2015 (the Act) and constitutes our slavery and human trafficking transparency statement for the financial year ended 31 August 2022. This statement supplements our slavery and human trafficking transparency statement as of June 2021 and explains the further steps that we have taken in the financial year to identify and reduce the risk of modern slavery occurring within the company and our supply chains, and how we plan to develop enhanced policies and procedures to improve our processes going forward.
Our organisation
Nord Anglia Education is currently a family of 81 premium international schools, based in 32 countries around the world. We offer personalised, inspiring learning to more than 70,000 students between 2 and 18 years old. We have around 15,000 employees most of whom are based at our Schools. Our staff are largely directly employed and are not in any category which is generally seen to be vulnerable to modern slavery, so our focus is to ensure there are policies and procedures in place for our contractors and suppliers.
Supply Chain
Nord Anglia Education Limited uses many suppliers both domestic and international to support our operations and activities. These suppliers mostly supply services to us relating to marketing and recruitment, venues and events, IT delivery and support, our offices and premises, agency workers and consultants, training providers, academic materials, travel, and professional services. We also procure a limited amount of goods in the form of office supplies, furniture, IT hardware and other materials used in our day-to-day operations.
Policies and Processes
Nord Anglia Education Limited is committed to combatting modern slavery, and that commitment is reflected in Nord Anglia Education’s global policies and in the expectations we impose upon our supply chain and their respective procurement functions.
In its last Modern Slavery Statement, Nord Anglia Education Limited reported that it was developing a number of measures to help achieve this commitment. Since then, Nord Anglia Education Limited has been successful in delivering the following measures:
- Continuing to ensure we have an anti-slavery clause where appropriate in our centrally procured new and renewed contracts with suppliers; this requires our suppliers to certify that they are complying with the Act and associated legislation.
- Delivered training with those employees who procure goods and services. This includes training on the standard supplier terms and conditions expected to help combat anti-slavery in product/service contracts.
- Updated relevant processes and policies, including an updated Procurement Policy, Procurement Guidance and a new Modern Slavery Policy, all available on the NAE intranet. This will help ensure that modern slavery is addressed and, where appropriate, incorporating ethical trade, corporate social responsibility and human rights.
- Continued to ensure NAEs updated Supplier Due Diligence form is used to help ensure that our partners will comply with the Act and associated legislation
- Implemented enhanced due diligence and risk checks on significant contracts that evaluate potential suppliers in relation to modern slavery before they enter the supply chain.
- Maintained standard supplier agreement templates to include modern slavery and human trafficking warranties and undertakings where appropriate. Pursuant to these terms, Nord Anglia Education Ltd makes it incumbent upon its suppliers to respect and comply with all applicable laws, including the Act, and Nord Anglia Education Ltd reserves the right to terminate its commercial partnership with any supplier who is found to be in breach of, or who fails to comply with the Act. This applies to both domestic and international suppliers.
We also have a wider policy framework reflecting our approach to this issue, which are reflected in particular in the following internal policies:
- Modern Slavery Policy
- Code of Conduct and Ethics Policy
- Anti-Corruption and Bribery Policy
- Whistle Blower Protection Policy
- Procurement Policy
- Background Checking Policy
- Nord Anglia Education Safeguarding Policy
Planned activities for FY2022/23
In the next financial year, Nord Anglia Education Limited will build on the work already done to further develop its anti-modern slavery policies and procedures. Planned activities include:
- Update relevant processes and policies, including an updated Procurement Policy, Procurement Guidance and a new Modern Slavery Policy, where applicable, to reflect changes in legislation and/or best practice.
- Continue to ensure that modern slavery is addressed throughout the procurement process by applying enhanced due diligence and risk checks on significant contracts that evaluate potential suppliers in relation to modern slavery before they enter the supply chain.
- Reissue NAEs code of conduct which will iterate the requirement for all staff to work in compliance with all relevant policies, including but not limited to the Modern Slavery Policy.
- Implement modern slavery awareness training within NAEs new joiner induction programme.
- Provide continued support and training opportunities to staff on how to ensure we are addressing modern slavery in our supply chain.
- Develop and roll-out a new document management system to ensure that the inclusion of key anti-slavery terms in the renewal of school-based contracts can be continuously reviewed and managed.
- Continue to raise awareness across the company via internal communication channels, with links to website www.modernslavery.co.uk
- Blacklist any organisations found to be non-compliant with NAE standards and policies.
Approval
This statement has been approved by the Board of Directors of Nord Anglia Education Limited on 2 September 2022.
