This statement constitutes our modern slavery and human trafficking transparency statement as at February 14, 2019. We will update this statement in our financial year 2019/20. This statement explains the steps that we have taken to date to ensure and prevent modern slavery from occurring within the company and our 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 61 premium international schools, based in 28 countries around the world. We offer personalised, inspiring learning to more than 61,000 students between 2 and 18 years old. We have around 12,500 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.
Nord Anglia Education Ltd uses a large number of 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 Ltd is committed to work within applicable laws and as the Act is an integral part of the UK legal framework, its requirements are reflected in the Nord Anglia Education Ltd global policies. These policies set out our commitment to comply with the Act and the expectations it imposes upon our supply chain and their respective procurement functions to ensure their own compliance with the Act. Nord Anglia Education Ltd are developing a number of measures to help achieve this, including:
- Having an anti-slavery clause in all our new and renewal 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 that supports the aims of the Act:
- 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, Nord Anglia Education will build on the work already done to further develop our anti-modern 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. 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.
- Continue to raise awareness across the company via internal communication channels, with links to website www.modernslavery.co.uk
This statement is made in accordance with section 54(1) of the Act. This statement has been approved by the Nord Anglia Education Board of Directors and constitutes our modern slavery and human trafficking statement up to the date of publication of this Statement.