POLICIES & PROCEDURES:
MODERN SLAVERY
This statement sets out Crosby Training’s actions to understand all potential modern slavery risks related to its business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business and or in that of our partner organisations. This statement relates to actions and activities during the contract year 1 August 2019 to 31 July 2020.
Crosby Training recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Crosby Training is absolutely committed to preventing slavery and human trafficking in our business activities, and to ensuring that any of our partner organisations are free from slavery and human trafficking
ORGANISATIONAL STRUCTURE
This statement covers the activities of Crosby Training. We do not subcontract the delivery of our training but work with a diverse range of organisations to support the employability needs of our learners (referred to as our partner organisations).
Crosby Training is aware of its legal responsibility, and ensures that our partner organisations comply with the Act. This includes policies, risk assessment, due diligence and training requirements.
RELEVANT POLICIES
Crosby Training has a number of policies that assist in preventing slavery and human trafficking in its operations, including:
- Whistleblowing Policy
Crosby Training encourages all of its workers, customers and other partner organisations to report any concerns related to the direct activities, of the organisation or our partner organisations. The Whistleblowing Procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Safeguarding Policy
Crosby Training provides advice and guidance to staff that includes references to modern slavery and trafficking in the form of formal staff training. The legislation, and its implications for practitioners and learners, is clarified in Crosby Training’s Safeguarding Policy and in addition it is fully covered in face-to-face staff training packages during staff induction and in advanced training offered to key staff.
- Procurement Policy
Crosby Training does not use a supply chain for the delivery of the training. The company is committed to ensuring that our partner organisations adhere to the highest standards of ethics and are aware of their obligations under the Act and comply where necessary.
Any partner organisation that does not comply with the Modern Slavery Act 2015, or Crosby Training’s own policies and procedures, will be removed from Crosby Training’s list of partner organisations. They will not be considered as future partners unless they can demonstrate that these compliance requirements are met.
- Recruitment & Selection Policy
Crosby Training uses reputable employment agencies to source staffing requirements. It verifies the practices of any new agency used before accepting workers from that agency.
Crosby Training ensures that all approved recruitment agencies conduct all relevant pre-recruitment checks and provide evidence that all such checks have been conducted.
- Anti-Bribery and Corruption Policy
Crosby Training is committed to the highest standards of ethical conduct and integrity in its business activities. The company will not tolerate any form of bribery or corruption by its employees or any person or body operating on its behalf.
PERFORMANCE INDICATORS
Crosby Training has introduced performance targets to measure progress against reducing any risks of modern slavery occurring in any part of our services. Progress on the performance targets are analysed on a regular basis. The performance targets are set out below:
• All staff trained in the background to modern slavery. Target 100%.
TRAINING
Crosby Training ensures that key staff undertake training on modern slavery, where deemed necessary, and engages with external training providers, as appropriate.
This statement has been quality assured by Crosby Training and will be reviewed and updated annually as part of the Self Assessment Report and Quality Improvement Plan.
Policy doc: Modern Slavery Policy: V2022 MP Review date: Jan 2026
