Section 54 of the Modern Slavery Act 2015 - slavery and human trafficking statement
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, 2019. This statement supplements our slavery and human trafficking transparency statement as at 14 February, 2019 and explains the further steps that Nord Anglia Education Limited has taken in the financial year ended 31 August 2020 to identify and reduce the risk of modern slavery occurring within our business and supply chains, and how we plan to develop enhanced policies and procedures to improve our processes going forward.
Nord Anglia Education is a family of, currently, 66 premium international schools based in 29 countries around the world. Nord Anglia Education offers personalised, inspiring learning to more than 66,000 students between 2 and 18 years old. Nord Anglia Education employs around 13,500 employees globally most of whom are based at international schools. 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.
Nord Anglia Education Limited uses a number of suppliers both domestic and international to support operations and activities. These suppliers mostly supply services 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 global policies and in the expectations we impose upon our supply chain and their respective procurement functions. In our last statement, we reported that we were developing a number of measures to help achieve this commitment. During the financial year ended 31 August 2019, Nord Anglia Education Limited has been successful in delivering the following measures:
▪ Having 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.
▪ Awareness raising with those employees who procure goods and services.
▪ The appointment of a Global Procurement Director whose role includes ensuring that we use best practice in our procurement and supply chain management.
▪ Relevant due diligence checks with our suppliers and a requirement within our partnership agreements that our partners will comply with the Act and associated legislation.
We also have a wider policy framework reflecting our approach to this issue, which are reflected in particular in the following internal policies:
▪ 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 FY19/20
In the next financial year, we will build on the work already done to further develop our antimodern slavery policies and procedures. Planned activities include:
▪ Update relevant processes and policies across the organisation to ensure that modern slavery is addressed and, where appropriate, incorporating ethical trade, corporate social responsibility and human rights.
▪ Ensuring that modern slavery is addressed throughout the procurement process by applying due diligence and risk checks that evaluate potential suppliers in relation to modern slavery before they enter the supply chain.
▪ Develop 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.
▪ Provide training opportunities to staff on how to ensure we are addressing modern slavery in our supply chain.
▪ Conduct checks on existing supplier agreements to ensure that appropriate clauses and policies are in place.
▪ Continue to raise awareness across the company via internal communication channels, with links to website www.modernslavery.co.uk.
This statement has been approved by the Board of Directors of Nord Anglia Education Limited and has been signed below by Andrew Fitzmaurice, a Director of Nord Anglia Education Limited.
Andrew Fitzmaurice, Director
Dated 12 June 2020