Modern slavery statement
Our modern slavery statement.
No child's educational success should be limited by their background.
Transforming education with great teachers, leaders and networks.
Too many children do not get the education they deserve. Where they're from should not affect where they're going, yet too often it does.
We seek to develop and support teachers, leaders and networks who are determined to make a difference where it is needed the most. Teach First is committed to continuously improving our practices to ensure that modern slavery and human trafficking are not present within our own organisation or our supply chains. We strive to act ethically and with integrity in all our activities.
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes Teach First’s modern slavery and human trafficking transparency statement as of February 2022.
This statement explains the steps that have been taken by Teach First to date and how we plan to continue developing and implementing a proactive approach to the prevention of modern slavery.
Teach First operates in the education sector, recruiting, training and developing teachers in some of the most disadvantaged schools across England. Teach First works collaboratively with universities from across England to deliver initial teacher training and Masters programmes. In addition to these programmes, we run a number of professional development opportunities for teachers and school leaders. Contractual governance and operational delivery of all of our programmes is maintained through teams based at our headquarters in London and in regional teams across England where the programmes operate. All teams report ultimately into the charity’s Executive Committee, headed by the CEO, which has oversight of compliance with all relevant legislation including the Modern Slavery Act 2015 (the Act). The CEO and Executive Committee report to the trustees of the charity who bear ultimate legal responsibility for the charity’s activity.
Teach First uses a number of suppliers to support our operations and activities. Our suppliers are predominantly UK based and are therefore required to be compliant with UK legislation. These suppliers mostly provide services relating to marketing, recruitment, venues and events, IT delivery and support, offices, agency workers, consultants, training, travel and professional services. We also procure a limited amount of goods in the form of office supplies, furniture, IT hardware and other materials used in our day-to-day operations.
The ongoing coronavirus pandemic since 2020 has presented an increased health and safety risk for all employees and those of the suppliers we work with. In response to this, we have had to change the way we deliver our core operations meaning that much of the work we do with teachers and school leaders has moved to a blended, flexible delivery model; when restrictions have allowed, we have worked in person with our stakeholders and during peak periods of coronavirus infections we have moved our engagement to virtual and online services and support. This has had a direct impact on the types of suppliers we work with; since 2020 we have significantly increased our reliance on IT and new technology tools and we have seen a continued reduction in our use of travel, venues and events and hospitality suppliers. In line with government guidance our employees have continued to work from home. To ensure that colleagues are able to work from home safely, we have purchased additional office equipment from suppliers with whom we already had an established contractual relationship in place.
Our supply chains
Due to the nature of our business, we are predominantly a consumer of services, and not products or raw materials. Compared with other industry sectors the risks associated with modern slavery in our supply chain are low. Nonetheless, the charity is committed to proactively monitoring and managing any risks to ensure that our supply chains remain free of slavery and we have implemented a number of measures to help achieve this, including:
- Our standard form contracts (which we use where possible with our key suppliers) include an anti-slavery clause; this requires our suppliers to ensure that they are complying with the Act and associated legislation.
- Contracts also include a right to audit suppliers annually on their compliance with the Act.
- Awareness raising with senior employees who procure goods and services.
- The procurement team continues to drive the use of best practice in procurement and supply chain management.
- The Procurement Manager has completed the CIPS Ethical Procurement and Supply Chain Training and acts as the modern slavery ‘champion’ across the charity.
- Utilising an external Internal Audit provider to evaluate and make recommendations to improve the overall effectiveness of risk management, control and processes across the charity.
Teach First is an accredited Living Wage provider. As part of this pledge, we have committed to paying the current living wage to all directly employed staff, including employees, campus representatives, agency/temporary workers, and casual workers. We have also committed to paying the living wage to all regular third party contracted staff which includes staff employed via our key sub-contracts (such as University tutors) and cleaning services at our London office. The living wage requirement is included in our mandatory requirements for all large-scale procurements and in our standard form contracts.
When recruiting temporary workers, we utilise the services of one main recruitment supplier in London and a small number of other ad hoc suppliers both in London and regionally, all of whom are reputable agencies and with whom we have agreed Terms and Conditions for each appointment. These suppliers and terms are reviewed annually. To minimise any risk, we have taken the following steps to ensure that such recruitment complies with the Act:
- We are a Real Living Wage employer and have reviewed the pay structure for all temporary agency staff to ensure conformity with the national Real Living Wage.
- Our agreements ensure that suppliers provide the necessary ‘right to work’ checks for all temporary staff.
- Our agreements ensure that we are fully compliant with agency worker regulations including that, after 12 weeks in an assignment, charge rates are automatically raised in line with the regulations.
Policies and processes
Teach First is committed to continued policy development to ensure that we keep up to date with all changes in legislation, including full compliance with the Modern Slavery Act.
It is a condition of our tendering and contracting process that all key sub-contractors can demonstrate full adherence to key employment legislation. This aims to ensure that the welfare and well-being of all employees working or participating on our programmes are fully protected.
As part of our high value/risk tender processes, all major sub-contractors are required to warrant to the charity that they are fully compliant with all employment, equality and environmental legislation and that, where applicable, they are compliant with the annual reporting requirements contained within section 54 of the Modern Slavery Act.
We have a wide policy framework that supports the aims of the Modern Slavery Act:
- All Teach First staff are required to complete annual Child Safeguarding and data training
- Anti-Fraud, Bribery and Corruption Policy
- Whistleblowing Policy
- Grievance Policy
- Recruitment & Selection Policy
- Pay Policy
- Procurement and Contracting Policy
- Discrimination, Harassment and Bullying Policy
- Acceptance and Refusal of Donations Policy
Due Diligence and Risk Management
As part of the procurement and contracting process with all key sub-contractors and suppliers, Teach First carries out detailed financial and legal due diligence checks for all large supply arrangements.
The charity also carries out risk assessments for programmes and projects that are managed by the charity; this includes risk management measures such as contract risk registers and cross-functional team steering groups to ensure contract and risk oversight of all the programmes. These are constantly reviewed by senior management to ensure their continued effectiveness in managing any risk. Due to the nature of the sector that Teach First operates in, and the close regulation and supervision it receives from UK Governmental departments, the likelihood of compliance issues occurring is very low. Our key subcontractors are predominantly UK universities with whom we have established long-term working relationships. Prior to contract award we have completed robust due diligence checks on these institutions and signed contracts that include sub-contractor obligations under the Act.
The procurement team completes an annual risk mapping exercise of current supply chains across all departments which includes a RAG rating of all key suppliers in relation to the risks of modern slavery. Where applicable they check all our key suppliers to ensure that they have a robust Modern Slavery statement in place. In our 2020/21 financial year, Teach First worked with 12 new suppliers to deliver contract values over £10K all of which were rated green in terms of modern slavery risk due to the nature of the services provided, contractual arrangements and the policies and processes in place.
We have identified that activities employing staff on a temporary/casual basis could present an increased risk. These activities are carried out by a small number of suppliers for events, catering, hospitality and the production of branded goods and stationery; we believe the risk to be low as a result of the internal processes we have implemented with suppliers in these industries, as described above. Due to the coronavirus pandemic our use of suppliers in these sectors has remained significantly lower than in previous years.
The procurement function continues to assess and review areas of the Charity’s operations where the Act could be contravened through ongoing risk identification and supply chain management. Any suppliers identified as being from high-risk industries or locations will be further monitored while they remain part of our supply base. They have developed a supplier questionnaire to learn more about the organisations and suppliers that Teach First works with. This will be shared with all key suppliers to help inform and understand any current or emerging risks of exposure to modern slavery across the supply chain and to learn from other effective practices and systems and processes that are being used by suppliers. Moving forwards, the questionnaire will be issued annually to new suppliers and the data will be used on an ongoing basis to track suppliers’ compliance. Where any risks are identified they will be escalated to the CFO and Director of Governance, Legal and Compliance. Suppliers will be contacted to agree a time-bound action and improvement plan which will be closely monitored on a regular basis.
Teach First will not accept donations from organisations or individuals whose principal business is considered to be in conflict with the charity’s aims and policies, including modern slavery and human trafficking. We apply a consistent and rigorous approach to our due diligence screening for suitability when working with new corporate partners and donors.
Culture and training
Teach First is funded from a range of public and private sources and, as a charity, is committed to ensuring that the maximum value, benefit, and impact is achieved from the funding that we receive. Value for money is seen as a key performance indicator and it is essential for the prosperity and reputation of the charity that we are able to evidence that our funding is being used in the most effective way.
The ethical and moral culture that Teach First promotes is part of every employee’s training from their initial induction until they leave the organisation. Our organisation’s principles of speaking up, remaining focused and succeeding together also reflect this. All employees are required to complete mandatory child safeguarding and equality, diversity and inclusion training annually. All staff are also offered the opportunity to take a further module dealing with employment legislation (in addition to the mandatory training that members of the HR department undertake).
As a charity working to achieve equality in the education system, we require that every prospective candidate for employment with us can demonstrate their belief in our values as part of our recruitment process. This culture ensures that employees feel confident in flagging any failings that they may encounter while working for the organisation, including the Modern Slavery Act. Our Whistleblowing Policy further encourages staff to report concerns in the workplace.
Incidents in 2021
To date, there have been no reported incidents of modern slavery by Teach First or suppliers to Teach First in 2021.
Over the next 12 months we will continue to build on the work already done to further develop our anti-modern slavery policies and procedures. Planned activities include:
- Creation of a standalone responsible procurement policy and related principles (including a Supplier Code of Conduct); we will raise awareness across the organisation by launching this via internal communication channels and externally via our website.
- Development of a supplier management framework to clarify roles and responsibilities and provide guidance on effectively managing key supplier contracts across the organisation.
- Providing specific Modern Slavery Act guidance to key individuals and teams across the organisation who are responsible for managing significant contractual relationships.
- Issuing the supplier questionnaire, collating responses, escalating any current or emerging risks and following up as required.
- Modern Slavery RAG rating to be included in Contracts & Procurement Quarterly Performance Reports.
This statement was approved by the Chair of the Board of Trustees on 8 February 2022 and is signed by Russell Hobby, Chief Executive Officer, Teach First.