This statement sets out actions of Total Training. (the organisation) 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 its own business and its supply chains. The organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking. It is committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains are free from slavery and human trafficking.
ORGANISATIONAL STRUCTURE AND SUPPLY CHAINS
Total Training. is a training provider based based across three sites (Head Office: Olton, Birmingham, Midlands CPCS Test Centre, Bickenhill, Solihull and North East Centre: Hartlepool). It delivers education and training to learners on commercial courses and public funded programmes. The majority of its learners come from the Midlands and the North East. Courses and qualifications have been and are delivered Nationwide e.g. London, Manchester, Newcastle. The organisation has a supply chain covering staffing resources and operational activities including, but not limited to: associate trainers, testers and facilities. The organisation is aware of its responsibility under the Act.
Total Training. has a number of policies that assist in preventing slavery, human trafficking and other forms of exploitation in its operations, including:
Environmental Sustainability P
Anti-bribery & Corruption Policy
Business Code & Ethics
|Total Training. is committed to ensuring that its subcontractors and suppliers adhere to the highest standards. Further work will be undertaken to ensure all procedures fully meet the requirements of the Act.|
Managing H&S of Young People at Work Policy
Staff Safeguarding & Safer Recruitment Policy
Prevent Vulnerability to Violent Extremism Policy
|Total Training. has established recruitment processes to ensure that comprehensive pre-employment checks take place relating to DBS, Barring List, proof of identity, right to work, references and medical clearance.|
|Staff Code of Conduct
Bullying and Harassment Policy
Complaints & Compliments Policy
|Clear policies are in place to ensure that staff
receive fair treatment from the point of
application and throughout their employment.
Total Training.’s Code of Conduct makes it clear to employees the actions and behaviour expected of them when representing the
organisation. There are policies that enable staff to raise any complaints, grievances or other matters of
concern that they have. Staff also have access to line managers, 1-2-1s and appraisals, as well as access to HR advice and guidance.
|Total Training. encourages all its employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. The Whistleblowing Procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.|
Learner Support and Safeguarding
The organisation also has in place the following policies which are designed to ensure that
learners are protected from slavery and human trafficking:
Bullying & Harassment Policy
Control of Visitors in the Workplace Policy
Information Handling of Personal Data Policy
Lone Workers Policy
Promoting Learner Well-being Policy
Retention, Attendance, Absence & Withdrawal Policy
|All staff are required to undertake mandatory
safeguarding training, including annual
updates. The Group also has in place a
dedicated Safeguarding Team, including senior
and deputy lead safeguarding officers, and
locally agreed multi-agency procedures for
supporting learners at risk of harm.
The organisation undertakes appropriate financial and due diligence checks when considering taking on new suppliers and regularly reviews its existing suppliers to ensure they meet their regulatory obligations. Appropriate assurance is sought that all subcontractors and suppliers engaged by the organisation comply with the Act. Consideration will also be given to appropriate operational key performance indicators to monitor this compliance.
The main areas of risk in relation to slavery and human trafficking arise from the following areas:
- Supply of goods and services including through supply chains which may have involved human slavery, trafficking and other forms of exploitation. To mitigate this risk, the organisation actively promotes the use of consortia when procuring goods and services, as these already have in place stringent and detailed contracts and due diligence processes to ensure suppliers are not involved with slavery, human trafficking or any other illegal activity.
- Learners studying with the organisation who may be subject to human slavery, trafficking and other forms of exploitation outside of the organisation’s environment. These learners may disclose this information to organisation staff. The organisations dedicated safeguarding and reporting procedures will ensure that where disclosed, such information will be dealt with appropriately and referred within multi-agency agreed timelines for safeguarding leaners at risk.
- Staff employed by the organisation may also be subject to human slavery and other exploitation outside the organisation environment. The organisation’s recruitment policies together with its employment policies and processes provide opportunity for this information to be disclosed and for subsequent action to take place, as appropriate.
- The organisation is considering any additional training required for any sectors which may be deemed to be higher.
TRAINING AND AWARENESS RAISING PROGRAMME
The organisation will ensure that key staff will undertake training on modern slavery, where deemed necessary and will engage with external training providers, as appropriate.
The organisation will continue to raise the awareness of the basic principles of the Modern Slavery Act 2015, including but not limited to:
- How employers can identify and prevent slavery and human trafficking;
- What employees can do to flag up potential slavery or human trafficking; issues;
- What external help is available, for example through the Modern Slavery Helpline.