Modern Slavery and Human Trafficking Policy

Sponsor: Chief Finance Officer
Subject Matter Expert: Group Finance Director

1. Purpose and Scope

This policy applies to all employees of Lifetime Group, whether permanent or fixed term. This policy provides a framework within which all employees can work to support the Group’s mission, vision and values. Failure to adhere to the objectives and measures in this policy may result in disciplinary action being taken.

As a market leading training provider, we acknowledge our responsibility to take a robust approach to slavery and human trafficking and to comply with all principles of the Modern Slavery Act 2015. This policy sets out how the Group aims to prevent opportunities for modern slavery to occur within Group companies, or any areas of our supply chain, and relates to actions and activities during the financial year 1 August 2023 to 31 July 2024.

The scope of our business is within the United Kingdom only. Given the nature of our supply chain, we do not deem any activities, or countries in which we operate, as high risk in relation to modern slavery.

This policy supersedes any previous policies prior to its issue date, does not form part of an
employees’ contract of employment and may be amended by the Company at any time.

2. Principles

Modern slavery is a criminal offence under the Modern Slavery Act 2015. Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

3. Responsibilities and Due Diligence

It is the responsibility of all employees to prevent and identify any risks associated with slavery and human trafficking within the workplace and supply chains. All employees and suppliers are encouraged to report any concerns using the appropriate reporting lines.

The Group is committed to complying with The Modern Slavery Act 2015 and has a zero-tolerance policy towards modern slavery of any kind. We work hard to assess and monitor all business relationships and employees to ensure fair and respectful treatment for all.

The Group are comfortable from our due diligence that there is no evidence of modern slavery or human trafficking in our organisation. The Group undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers and their policies. Should any supplier not meet the standards set out in this policy and our code of conduct, the Group would consider invoking sanctions, including the termination if the business relationship.

4. Performance Indicators

The following key performance indicators are implemented for all employees across the Group:

  • All employees will read and understand the policies outlined above (including this one related to Modern Slavery) and, where appropriate, receive additional training
  • All new employees will receive training on all the relevant policies in their standard induction programme
  • All suppliers will provide such co-operation and information that the Group reasonably requires in order to confirm compliance with our code of conduct; this includes, but is not limited to, providing written confirmation as to compliance with the Lifetime Training Group code of conduct, on request, allowing the Group to carry out (or commission others to carry out) compliance checks and audits
  • All Policies will be published on the company website and the Group can provide written copies should anyone request it
  • All staff will have clear reporting lines so any new updates can be disseminated throughout the business quickly and easily, and also be a clear channel for raising any concerns (re: Whistleblowing Policy)

5. Further Support

Should you have any questions relating to this Policy please raise with your line manager or a member of the Finance Team.

6. Associated Policies and Guides

The Group operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing Policy
  • Employee Code of Conduct
  • Corporate Social Responsibility