MODERN SLAVERY AND HUMAN TRAFFICKING POLICY

Accelerate International Academy Ltd (AIA)

Approved By: Senior Leadership Team
Designated Safeguarding Lead: Kimberley Hatherall
Review Cycle: Annual or following statutory updates
Effective From: 01 May 2026

 

  1. Policy Statement

Accelerate International Academy Ltd (AIA) is fully committed to preventing modern slavery and human trafficking in all aspects of our operations, delivery, partnerships, and supply chains.

AIA recognises its responsibilities under the Modern Slavery Act 2015 and is committed to acting ethically, transparently, and with integrity in all business relationships. We operate a zero-tolerance approach to modern slavery and are dedicated to ensuring that it does not occur within any part of our organisation or supply chain.

This policy applies to all employees, directors, freelancers, contractors, volunteers, delivery partners, subcontractors, and suppliers engaged by AIA.

2. Scope

This policy applies to all individuals and organisations working with or on behalf of AIA, including:

  • Permanent and temporary employees
  • Freelancers and associates
  • Directors and trustees (where applicable)
  • Volunteers and interns
  • Subcontractors and delivery partners
  • Suppliers and service providers
  • Learners and programme participants (from a safeguarding perspective)

3. Definitions

Modern slavery is a serious criminal offence and a violation of fundamental human rights. It includes:

  • Slavery: Exercising ownership over an individual
  • Servitude: The obligation to provide services under coercion
  • Forced or compulsory labour: Work undertaken under threat or penalty
  • Human trafficking: Recruitment, transport, or harbouring of individuals for exploitation

4. Legal and Regulatory Framework

AIA operates in full alignment with relevant legislation and guidance, including:

  • Modern Slavery Act 2015
  • Safeguarding Vulnerable Groups Act 2006
  • Working Together to Safeguard Children (HM Government guidance)
  • Prevent Duty Guidance (where applicable)
  • ESFA Funding Rules and compliance requirements (where applicable)
  • Ofsted Education Inspection Framework safeguarding expectations

5. Responsibilities

5.1 Senior Leadership (AIA Leadership Team)

  • Ensure full organisational compliance with this policy
  • Promote ethical practice across all operations and partnerships
  • Approve and review this policy annually
  • Ensure adequate resources are in place for implementation

5.2 Designated Safeguarding Lead (DSL)

  • Acts as the lead contact for all safeguarding and modern slavery concerns
  • Ensures appropriate escalation to external agencies where required
  • Maintains accurate records of concerns and actions taken
  • Ensures staff training and awareness is up to date

5.3 Staff, Contractors, and Delivery Personnel

  • Remain vigilant to signs of modern slavery and exploitation
  • Report any concerns immediately via safeguarding procedures
  • Complete mandatory safeguarding and modern slavery awareness training
  • Act in accordance with AIA’s ethical standards at all times

5.4 Procurement, Partnerships, and Subcontracting

  • Undertake appropriate due diligence on all suppliers and partners
  • Ensure contractual safeguards include anti-slavery obligations
  • Escalate or terminate relationships where risks are identified

6. Risk Assessment

AIA acknowledges that modern slavery risks may arise in:

  • Recruitment and engagement of vulnerable learners (including NEET individuals)
  • Subcontracted delivery arrangements
  • Freelance or casual labour within service delivery
  • Supply chains including IT, venues, marketing, and outsourced services
  • Employer engagement and work placement activity

AIA mitigates these risks through:

  • Robust safeguarding and safer recruitment practices
  • Partner due diligence and onboarding checks
  • Clear contractual requirements relating to ethical conduct
  • Ongoing monitoring and review of supply chain relationships

7. Due Diligence and Supply Chain Management

AIA is committed to ensuring that all parts of its supply chain are free from modern slavery and exploitation.

We achieve this by:

  • Conducting risk-based due diligence on suppliers and subcontractors
  • Including anti-modern slavery clauses in all contracts
  • Requesting evidence of compliance where appropriate
  • Avoiding engagement with high-risk or non-compliant providers
  • Terminating relationships where breaches or risks are identified

8. Safeguarding and Learner Protection

As a training provider working with potentially vulnerable individuals, AIA places safeguarding at the centre of all activity.

We ensure that:

  • Safeguarding is embedded across all programmes and delivery
  • Staff are trained to identify and respond to exploitation risks
  • Learners have safe, accessible reporting routes
  • Concerns are escalated appropriately and promptly
  • We work in partnership with Local Authorities and safeguarding bodies when required

9. Training and Awareness

AIA ensures all staff and associates receive appropriate training, including:

  • Safeguarding and child protection awareness
  • Understanding modern slavery indicators
  • Reporting procedures and escalation routes
  • Ethical and professional conduct expectations

Enhanced training is provided to:

  • Designated Safeguarding Lead(s)
  • Senior leadership team
  • Recruitment, delivery, and partnership staff

10. Indicators of Modern Slavery

AIA staff are trained to identify potential signs of exploitation, including:

  • Individuals appearing fearful, anxious, or withdrawn
  • Evidence of control by another individual
  • Lack of personal documentation
  • Poor living conditions or signs of neglect
  • Restricted freedom of movement
  • Unpaid or underpaid excessive working hours
  • Scripted or inconsistent communication

11. Reporting Concerns

All concerns must be reported immediately to the Designated Safeguarding Lead (DSL) at AIA.

Where appropriate, escalation may include:

  • Local Authority Safeguarding Teams
  • Police (in emergency situations)
  • Modern Slavery Helpline (UK): 08000 121 700

AIA guarantees that no individual will suffer detriment for reporting genuine concerns in good faith.

12. Whistleblowing

AIA is committed to maintaining a culture of openness and accountability. Staff, learners, and partners are encouraged to raise concerns without fear of retaliation.

Concerns may be raised confidentially in accordance with AIA’s Whistleblowing Policy.

13. Monitoring and Review

This policy is:

  • Reviewed at least annually
  • Updated in line with legislative, regulatory, or operational changes
  • Monitored through safeguarding audits and internal compliance checks

14. Accountability

Ultimate responsibility for this policy rests with the Senior Leadership Team of Accelerate International Academy Ltd (AIA).

Operational responsibility is delegated to the Designated Safeguarding Lead.