This statement constitutes Teach First’s modern slavery and human trafficking transparency statement as at March 2018.
This statement explains the steps that have been taken by Teach First to date to prevent modern slavery from occurring within the charity and our supply chains. The statement also sets out how we plan to develop enhanced policies and procedures to improve our processes going forward, to ensure that we are taking a proactive approach to the prevention of modern slavery.
Organisational Structure & Supply Chain
Teach First operates in the education sector, recruiting, training and developing new 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 programmes for Teach First ambassadors and other teachers including Leading Together, as well as other programmes aimed at improving careers education and employability guidance in schools. Contractual governance and operational delivery for these programmes is maintained through central teams based in London and local area teams based 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 the charity to ensure we are compliant 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. As part of our 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.
These suppliers mostly supply services to us relating to marketing, recruitment, venues and events, IT delivery and support, our offices and premises, agency workers, consultants, training providers, 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 charity has conducted a review of its supply base to assess if any major suppliers represented a risk to the Charity’s compliance with the Act.
We have reviewed our processes for recruitment of temporary workers. We utilise the services of one main supplier (95% of such recruitment) and seven smaller ad hoc suppliers, all of whom are reputable agencies and with whom we have signed contracts. These terms and such suppliers are reviewed annually by our HR department. To minimise any risk with our main supplier we have taken the following steps to ensure that such recruitment complies with the Act:
- We have reviewed the pay structure for all temporary agency staff to ensure that it conforms to that in place for our employed staff.
- Our contract ensures that the supplier provides the necessary ‘right to work’ checks for all temporary staff.
- Our contract ensures that we are fully compliant with agency worker regulations including that, after 12 weeks in an assignment, charge rates are automatically raised to rates compliant with the regulations.
- We have a contract in place for the provision of cleaning services for our London office. All staff working for Teach First as part of this contract are paid the London Living Wage as a minimum.
The charity is committed to ensuring that our supply chains remain free of slavery and have implemented a number of measures to help achieve this, including:
- Our standard form contracts with suppliers (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. - A right to audit suppliers annually on their compliance with the Act. - Awareness raising with those senior employees who procure goods. - The appointment of a Procurement Manager whose role includes ensuring that we use best practice in our 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.
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. To aid this Teach First has promoted a culture of awareness by using organisation-wide briefings to relay any significant changes to key employment legislation.
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 ensures that the welfare and well-being of all employees working or participating on our programmes is fully protected at all times.
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
- Equal Opportunities & Dignity at Work 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 .
As part of the due diligence process the charity carries out risk assessments for all programmes and projects that are managed by the charity; this includes risk management measures such as contract risk registers and cross-functional teams 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.
As part of the risk management around the Act, Teach First includes consideration of risks relating to modern slavery in the organisation’s internal risk register. This requires the charity to put in place mitigating actions to avoid non-compliance with the Act. The risk register also allows the Procurement Manager to regularly review the likelihood and impact of this risk and to assess if further actions need to be taken. Due to the nature of the sector that Teach First operates in, and the heavy regulation and supervision it receives from UK Governmental departments, the risks are regarded as minimal and the likelihood of them occurring very low.
As part of the ongoing procurement function the charity will continue to assess and review the areas of the organisation where the Act could be contravened.
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. This means that 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 at all times that our funding is being used in the most effective way.
Teach First is committed to ensuring that the drive for Value for Money does not compromise the obligations contained in the Act. The charity has fostered a culture of striving to achieve the best quality of service, goods and supplier available and this culture permeates the organisation and acts as a vital safeguard ensuring that goods or services purchased are provided by suppliers who respect and adhere to the Act. The charity does not look primarily to source the cheapest goods or suppliers and has communicated to staff via the Procurement Policy that a key part of our Value for Money framework is ensuring that the suppliers we select are compliant with the Act.
The ethical and moral culture that Teach First fosters is part of every employee’s training from their initial induction until they leave the organisation. In 2016 all employees undertook mandatory child safeguarding and equality and diversity training. This training is required to be refreshed by all staff every two years. All staff are also offered the opportunity to take a Human Resources 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 as part of our recruitment process that every candidate can demonstrate their belief in our values. This culture ensures that employees feel confident in flagging any failings that they may come across while working for the organisation and this includes the Modern Slavery Act.
- Over the next 12 months we will 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.
- Ensuring that modern slavery is addressed throughout the procurement process by implementing new due diligence and risk checks that evaluate potential suppliers in relation to modern slavery and identify improvements before they enter the supply chain.
- 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 such as our monthly ‘Connect’ newsletter and Intranet and publishing a full copy of the Modern Slavery Act 2015 (along with a simplified overview) on the Intranet to ensure it is accessible to all employees.
This statement has been approved and signed by Russell Hobby, Chief Executive Officer, Teach First