Modern Day Slavery Statement
SofiNo Education Ltd adopts a zero-tolerance policy towards modern slavery and human trafficking, and all forms of corruption, bribery, directly and indirectly associated with these criminal acts. Suppliers/contractors/service providers must take steps to identify and tackle any instances of modern slavery in supply chains.
SofiNo Education Ltd requires its suppliers/contractors/service providers to conform with the following Modern Slavery and Human Trafficking Code of Conduct in respect of addressing and eliminating forced labour in accordance with the Modern Slavery Act 2015.
Suppliers/contractors/service providers must also take the relevant action within their own supply chains to ensure modern slavery and human trafficking is eliminated.
- Policy Number: HR007
- Issue Number: 01
- Issue Date: 11/03/2025
- Next Review Date: 03/2026
- Originator: Operations
- Authoriser: Kelley Fray
- Service Type: All
- Policy Location: Teams/Policies
Definitions
Modern slavery is the term used within the UK and is defined within the Modern Slavery Act 2015 (the ‘Act’). The term is used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking.
Human trafficking is where a person arranges, or facilitates, the travel of another person with a view to that person being exploited.
Forced or involuntary labour
Recruitment fees
Confiscating or withholding documents
Contracts of employment
Deposits
Humane treatment
The workplace must be free from any form of harsh or inhumane treatment.
Disciplinary policies and procedures shall be clearly defined and communicated to all employees, and must not include any inhumane disciplinary measures, including: any corporal punishment, mental or physical coercion, verbal abuse of workers; sanctions that result in wage deductions, reductions in benefits or compulsory labour. The use or threat of physical or sexual violence, harassment and intimidation against a worker, his or her family, or close associates, is strictly prohibited.
Humane treatment
The workplace must be free from any form of harsh or inhumane treatment.
Disciplinary policies and procedures shall be clearly defined and communicated to all employees, and must not include any inhumane disciplinary measures, including: any corporal punishment, mental or physical coercion, verbal abuse of workers; sanctions that result in wage deductions, reductions in benefits or compulsory labour. The use or threat of physical or sexual violence, harassment and intimidation against a worker, his or her family, or close associates, is strictly prohibited.
Workplace equality
Wages and benefits
All employees must be paid at least the minimum wage required by applicable laws and shall be provided all legally mandated benefits. Wage payments must be made at regular intervals and directly to employees in accordance with national law and must not be delayed, deferred or withheld. Only deductions, advances and loans authorized by national law are permitted and, if made or provided, actions must only be taken with the full consent and understanding
of employees. Clear and transparent information must be provided to employees about hours worked, rates of pay and the calculation of legal deductions. All employees must retain full and complete control over their earnings.
Wage deductions must not be used as a disciplinary measure, or to keep employees tied to the employer or to their jobs. Employees must not be held in debt bondage or forced to work to pay off a debt. Deception in wage commitments, payment, advances and loans is prohibited.
Working hours
Freedom of movement and personal freedom
Grievance procedure
Human Trafficking
Communication and awareness of this policy
All staff are made familiar with the anti-slavery policy, particularly in respect of the safeguarding of vulnerable people, and they are expected to report any concerns in line with the service’s safeguarding policies and procedures.
Staff responsible for the procurement of goods and services will receive training so that they can ensure that the service is never implicated in any dealings that would render it vulnerable to accusations or charges that it might have breached modern anti-slavery law, and how to respond to any suspicions or evidence of breaches in the law.
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. We will adopt a continuous improvement approach to our training and development, sharing learning and best practice through bulletins, our intranet, policy updates, newsletters, peer meetings and themed activities.
We will continue to embed the principles through:
- providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
- ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
- ensuring that consideration of the modern slavery risks and prevention are added to
- our policy review process as an employer and procurer of goods and services
- making sure procurement strategies and contract terms and conditions include references to modern slavery and human trafficking
- continuing to take action to embed a zero-tolerance policy towards modern slavery
- ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices
Breaches of this policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with suppliers, contractors, business partners and any other individuals and organisations working with us or on our behalf if they breach this policy.
Accessible Information
Our policies in relation to the Modern Slavery Act 2015
The following policies are available upon request
- Code of conduct
- Whistleblowing policy
- Bullying and harassment policy
- Equality, Diversity and Inclusion Policy
- Safer Recruitment policy
Our policies in relation to the Modern Slavery Act 2015
The following policies are available upon request
- Code of conduct
- Whistleblowing policy
- Bullying and harassment policy
- Equality, Diversity and Inclusion Policy
- Safer Recruitment policy
SofiNo Education Ltd, 93 Marsh Lane, London, NW7 4LE
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