Modern Slavery Statement 2023-24

Modern slavery is a crime that affects millions of individuals around the world. The Modern Slavery Act 2015 defines these offences as those of ‘slavery, servitude and forced or compulsory labour’ and ‘human trafficking’. Our Trust is committed to ensuring that modern slavery is not tolerated and encourages all those employed by the Trust, or associated with it, to take a proactive approach to tackling this type of crime. We believe that this is an essential expression of our Co-op values and Ways of Being.

Our trustees and senior executive leaders have not had cause to believe that modern slavery practices have occurred within the Trust or within its supply chains, but remain keenly aware of the need for continued vigilance.

1. Organisation Structure and supply chains

The Co-op Academies Trust is a multi-academy trust comprising 36 primary, secondary, post-16 and special academies across the North of England as of 31 August 2024. The Trust’s main business operations are in the provision of education. It is supported by a number of suppliers of various sizes.

The vast majority of the Trust’s supply chains are UK based and key contracts cover areas such as capital works, catering, estates management and catering, supply teaching  staff, other areas of staffing, uniform production, and educational and IT supplies. Eight of the Trust’s academies were contracted to a Private Finance Initiative (PFI).

2. Policies in relation to slavery and human trafficking

Our Trust is committed to ensuring that there is no modern slavery or human trafficking in any of our academies or any aspect of our business. The Trust is committed to acting ethically and with integrity in all its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in its business. The following key policies detail our approach to protecting pupils and staff and ensuring our supply chains are free from modern slavery and trafficking:

• Anti Slavery and Human Trafficking Policy
• Safer Recruitment Policy
• Safeguarding and Child Protection Policy
• Whistleblowing Policy

3. Due diligence processes

Our Trust is making increasing use of cross-academy contracts with larger providers who have their own statements and policies in relation to modern slavery. Our Trust is also making increasing use of professional third party providers to manage our tender processes for identifying entering into consolidated contracts, which conduct relevant due diligence on the Trust’s behalf. This makes due diligence in relation to contractors more transparent and efficient. Our Trust would never knowingly issue contracts to suppliers who do not adhere to the Modern Slavery Act 2015.

Due diligence activities take place at schools and colleges that are due to join the Trust. Detailed human resources (HR), contracts and financial information is gathered as part of this and any irregularity is challenged prior to conversion, then addressed upon conversion if it is outstanding.

4. Risk assessment and management

Our trustees and senior executive leaders deem the risk of systemic modern slavery within the Trust itself to be very low. Recruitment to the Trust takes place within policy frameworks and employees and volunteers are subject to legal checks, including Right to Work and DBS. Trustees and senior executive leaders are, however, clear on the need to maintain vigilance.

The Trust also deems the risk of systemic modern slavery within our supply chains to be low. This is because procurement processes are such that reputable firms are contracted and, where cost-effective, larger contractors with their own modern slavery statements or policies are used.

5. Measuring effectiveness

The Trust’s Chief Financial Officer (CFO) was the named senior executive leader responsible for monitoring organisation-wide, day to day compliance with the Anti-Slavery and Human Trafficking Policy during the 2023-24 year.

Our Trust Board, often via its Finance and Resources Committee, receives reports of key procurement activity, including the approval of large contracts as the terms of the Trust’s financial delegations dictate.

6. Training on modern slavery and trafficking

All Trust staff received training and information on Part 1 of Keeping Children Safe in Education 2023, which includes reference to child criminal exploitation. All new staff receive information and training on our Anti Slavery and Human Trafficking Policy and whistleblowing procedures when they start work with our Trust.

7. Actions taken by the Trust

The Trust Board has approved a Trust-wide Safeguarding and Child Protection Policy, which already contains specific content on child criminal exploitation. The Trust Board has approved a Whistleblowing Policy to promote each person’s duty to raise concerns of wrongdoing and criminality. Any incidents of whistleblowing are routinely reported to the Chair of Trust Board as the nominated Trust Board link for these matters. The Trust Board has also approved a Scheme of Delegation and related financial authority levels, which sets out clear arrangements for the approval of contracts of varying values.

This statement was agreed by trustees on 24 October 2024.