Modern Slavery and Human Trafficking Statement
Introduction
This Modern Slavery and Human Trafficking Statement relates to actions and activities of Education Buying Group Ltd (‘the PSBO’).
It is not anticipated that EBG Ltd will employ staff directly, should this change then this policy would apply to those employees. EBG Ltd will engage with contractors, suppliers and partners through its day-to-day activities, and as such it will endeavour to apply these principles to each of them.
Where reference is made to staff, employees or contractors, these are defined as employees, volunteers, workers (e.g., agency workers, casual workers, freelance workers, contractors), work experience students, interns, self-employed persons, and anyone carrying out duties on behalf of EBG Ltd or who is perceived as representing EBG Ltd.
This statement sets down the PSBO’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff/contractors etc. are expected to report their concerns and management to act upon them.
Organisational Structure and Supply Chains
This statement covers the business activities of the PSBO which are as follows:
Procurement Advice | Procurement Management | Procurement Guidance | Consultancy | Category Management | Provision of procurement consultancy and outsourced management services for private and public sector
clients and charity organisations | Procurement | Contracting Authority
The PSBO currently operates in the following countries:
Wales | England | Scotland | Northern Ireland
Responsibility for the PSBO’s anti-slavery initiatives is as follows:
1.1
Policies: a Director is responsible for creating and reviewing policies
1.2
Risk Assessments: a Director is responsible for risk assessments in respect of human rights and measures designed to identify and address modern slavery and human trafficking.
1.3
Due diligence: a Director is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.
Training
To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the PSBO would require all staff to complete an online training course.
Policies
The PSBO is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms our intention to act ethically in our business relationships.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
2.1
Whistleblowing policy – the PSBO encourages all its workers, customers and other business partners to report any concerns
related to its direct activities or its supply chains.
2.2
Employee Handbook and Code of Conduct – the Employee Handbook and Code of Conduct sets down the actions and
behaviour expected of employees when representing the PSBO.
Due Diligence Processes for Slavery and Human Trafficking
The PSBO undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The PSBO’s due diligence process includes having suppliers complete our Due Diligence Questionnaire and also us building long-standing relationships with suppliers and making clear our expectations of business partners or evaluating the modern slavery and human trafficking risks of each new supplier or, where necessary, invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.
Performance Indicators
The PSBO uses the key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including requiring all staff to have completed training on modern slavery.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The PSBO’s Board of Directors endorses this policy statement and is fully committed to its implementation.