Modern Slavery and Human Trafficking Policy

Modern Slavery and Human Trafficking Policy

1. Introduction
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Dynamic Training UK Ltd has taken, and continues to take, to prevent modern slavery and human trafficking within our business and supply chains.
Modern slavery includes slavery, servitude, forced labour, and human trafficking.
Dynamic Training UK Ltd has a zero-tolerance approach to modern slavery in all its forms.

2. Our Organisation
Dynamic Training UK Ltd delivers apprenticeship training, adult education, and workforce development programmes in partnership with employers across the UK.
We work with a range of employers and subcontractors across the education and healthcare sectors and recognise that risks may exist within wider supply chains and placement environments.

3. Our Commitment
We are committed to:
•    Acting ethically and transparently in all business activities 
•    Preventing modern slavery and human trafficking in our operations and supply chains 
•    Ensuring safeguarding remains central to learner engagement and employer partnerships 

4. Risk Assessment
We assess the overall risk of modern slavery within our direct operations as low.
However, we recognise that risks may exist indirectly through:
•    Employer placement environments 
•    Subcontracted delivery partners 
•    External recruitment practices within supply chains 
We therefore maintain a risk-based approach to prevention and monitoring.

5. Policies and Controls
We operate the following controls:
•    Modern Slavery Policy 
•    Safeguarding Policy (including exploitation reporting pathways) 
•    Whistleblowing Policy 
•    Safer Recruitment Policy 
•    Code of Conduct 
•    Subcontractor Policy
These policies are reviewed annually and updated in line with legal and regulatory changes.

6. Due Diligence and Risk Management
We take a proportionate, risk-based approach to supplier and partner management:
•    Supplier onboarding checks including identity and legitimacy verification 
•    Assessment of labour standards and working practices 
•    Inclusion of modern slavery clauses in contracts 
•    Monitoring of subcontracted delivery partners 
•    Right to suspend or terminate relationships where concerns arise 
Higher-risk suppliers are subject to enhanced scrutiny.

7. Learner and Employer Safeguarding
As a training provider, we recognise learners may be vulnerable to exploitation.
We ensure:
•    Safeguarding training includes modern slavery awareness 
•    Employers are briefed on reporting obligations 
•    Concerns raised by learners are escalated through safeguarding procedures 

8. Reporting and Whistleblowing
We encourage all staff, learners, employers, and partners to report concerns.
Reports can be made via:
•    Line management 
•    Safeguarding team 
•    Confidential whistleblowing channels 
All reports are treated seriously, confidentially, and in line with safeguarding procedures.

9. Supplier Standards
We require all suppliers to confirm that they:
•    Comply with the Modern Slavery Act 2015 (where applicable) 
•    Provide safe and lawful working conditions 
•    Pay at least applicable minimum wage requirements 
•    Allow termination of contract where concerns arise 

10. Training and Awareness
We provide training on modern slavery and safeguarding:
•    At induction for all staff 
•    Annual refresher training for relevant roles 
•    Embedded awareness for learners as part of British Values and safeguarding content 

11. Performance Indicators
We measure effectiveness through:
•    Number and quality of safeguarding and modern slavery referrals 
•    Audit findings (internal and external) 
•    Supplier compliance checks 
•    Resolution time of reported concerns 
An increase in reporting is viewed positively as it reflects awareness and confidence in reporting mechanisms.

12. Governance and Responsibility
Ultimate responsibility lies with the Board and Governors.
Operational responsibility is held by the Designated Safeguarding Lead and Senior Leadership Team, who ensure implementation and monitoring.