Modern slavery statement
Our modern slavery statement.
Teach First’s mission is to build a fair education for all. We seek to develop and support teachers and leaders 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 at February 2020.
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 and Wales. Teach First works collaboratively with universities from across England and Wales to deliver initial teacher training and Masters programmes. In addition to these programmes we also run a number of CPD opportunities for school leaders. Contractual governance and operational delivery for these programmes is maintained through teams based at our headquarters in London and in regional teams across England and Wales 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 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.
Our Supply Chains
The charity is committed to ensuring that our supply chains remain free of slavery and has 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.
- 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.
- The appointment of an external Internal Audit provider to evaluate and make recommendations to improve the overall effectiveness of risk management, control and processes across the charity. They will review procurement in 2020.
In 2019, Teach First became an accredited Living Wage provider. As part of this process 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). The living wage requirement is now included in our mandatory requirements for all large scale procurements.
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 are able to 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:
- Child Safeguarding training
- All Teach First staff are required to complete mandatory 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
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 risks occurring is very low. Since our last statement, the procurement team has undertaken a mapping exercise of current supply chains across all departments and has checked all our main suppliers to ensure that they have a robust Modern Slavery statement in place where applicable. 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; in total these suppliers account for approximately 1.5% of our total annual spend. We believe the risk to be low: where the terms and conditions currently in place with these providers do not cover compliance with the Act, we have written to each to confirm our requirement of compliance with the Act in any activities with Teach First going forwards.
The procurement function continues to assess and review the areas of the organisation where the Act could be contravened on an ongoing basis and will further monitor these suppliers whilst they remain part of our supply base.
Teach First will not accept donations from organisations or individuals whose principal business is considered to 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 and benefit 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. All employees are required to complete mandatory child safeguarding and equality, diversity and inclusion training every two years. 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 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 2019
To date, there have been no reported incidents of modern slavery by Teach First or suppliers to Teach First in 2019.
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:
- Continuously updating our procurement and key policies across the charity.
- Providing specific Modern Slavery Act training to key individuals and teams across the organisation who are responsible for managing contractual relationships.
- Awareness raising across the wider organisation via internal communication channels and our website.
- Launch of a Supplier Code of Conduct for use in our tendering and contracting processes.
- Implementation of an annual contract review.
This statement was approved by the Chair of the Board of Trustees on 5 February 2020 and is signed by Russell Hobby, Chief Executive Officer, Teach First.