Modern slavery statement

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.

We have a zero-tolerance approach to human trafficking and modern slavery

NWCS Training Ltd is committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains.

We will not accept any form of discrimination, harassment or bullying and we require all of our managers to implement policies designed to increase equality of opportunity and inclusion for all employees including agency workers.

Who we are

NWCS Training Ltd provides apprenticeship and commercial training opportunities across the North West of England. We work with Government agencies, Local Authorities and Private Pay customers and work in partnership with all of our clients to deliver a high quality standard of service.

Our policies on slavery and human trafficking

This statement sets out the steps that NWCS Training Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

We have several internal policies to ensure that we are conducting business ethically and transparently. These include:

Whistleblowing Policy, aimed principally at our employees but also available to others working in our supply chains which encourages staff to report any wrongdoing which extends to human rights violations like Modern Slavery. All reports will be fully investigated and appropriate remedial actions are taken and we will work closely with social care and health providers ensuring that our policies and procedures dovetail with local procedures and best practice.
A robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard.

Every year we make progress on our commitment to prevent modern slavery and human trafficking while continuing the following practices:

Requirements for all new employees to provide original documentation (such as a passport) before they start working with us to verify their legal right to work in the UK.
Review of strategies and policies to ensure they reflect anti-slavery and human trafficking best practice.
A requirement for all staff to adhere to the Code of Conduct which includes requirements in relation to workplace behaviour and equality and diversity.

Our Supply Chain - mitigating risks

We aim to conduct due diligence on all suppliers before allowing them to become a preferred supplier. We will include an online search to ensure that particular organisations have never been convicted of offences relating to modern slavery and include our modern slavery policy as part of our contract with all suppliers. Suppliers will be required to confirm that no part of their business operations contradicts this policy. As part of our contract with suppliers, they will confirm to us that:

They have taken steps to eradicate modern slavery within their business.
They hold their suppliers to account over modern slavery.
For UK based suppliers, they pay their employees at least the national minimum wage/national living wage (as appropriate) and to ensure that within their supply chains, where UK based suppliers have overseas supply chains, that their employees’ pay is consistent with their national minimum wage requirements, working conditions are safe and fair, there is no child labour and working hours are not excessive.
We may terminate the contract at any time should any instances of modern slavery come to light.

Risk Assessments

Our supply chains include procurement of staff, consumables, facilities maintenance, utilities and waste management. We will conduct a risk assessment and ensure that further steps are taken to support the eradication of modern slavery, that staff understand how to recognise modern slavery and the appropriate safeguarding reporting processes are followed should there be concerns within our supply chains, with customers or suppliers.

Performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery is not taking place within our business or supply chain if:

No reports are received from employees, the public, or law enforcement agencies or local safeguarding teams to indicate that modern slavery practices have been identified

Direct Communication

The Company encourages members of the public or people not employed by us to write, in confidence, to raise any concern, issue or suspicion of modern slavery in any part of our business.

Safeguards

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. NWCS Training Ltd will accept and take serious concerns communicated anonymously. However, retention of anonymity does render investigations and makes validation more difficult and can make the process less effective.

Individuals are therefore encouraged to put their names to allegations. Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

Assessment of effectiveness in preventing Modern Slavery

We understand that modern slavery risk is not static, and will continue our approach to mitigating this risk. We will assess the risk via our internal auditing processes.

Responsibility for this Statement

This statement is made according to Section 54(1) of the Modern Slavery Act 2015 and constitutes the Modern Slavery and Human Trafficking statement of NWCS Training Ltd for the financial year ending 2022.

The responsibility for the prevention of modern slavery rests with the Head of Centre for ensuring that this policy and its implementation complies with our legal and ethical obligations. Managers at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

This statement has been approved by the Head of Centre of NWCS Training Ltd.

Date: 30th January 2023