E-ACT Modern Slavery Statement 2019-2020
This statement is made on behalf of the E-ACT Multi-Academy Trust (company number 06526376) pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. This statement relates to actions and activities during the financial year September 2019 to August 2020.
E-ACT recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is committed to preventing slavery and human trafficking within its activities and to ensuring that its supply chains are free from slavery and human trafficking.
This statement sets out E-ACT’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its business and supply chains.
Structure, business and supply chains
E-ACT is a multi-academy trust (MAT), working within some of the most economically deprived areas of the country. Our academy list can be found on our website.
E-ACT has three main areas of operations:
- A national level which oversees the business as a whole;
- A regional level which is responsible for a group of academies;
- A local level – e.g. an individual academy.
Our supply chains are UK based and key supply areas cover catering, maintenance/repairs, agency staff and cleaning.
We work to the highest professional standards and comply with all laws, regulations and rules relevant to our business. We expect the same high standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Policies, documentation and key relationships
The following key policies and documentation detail our approach to protecting our pupils and staff from modern slavery and ensuring our supply chains are free from modern slavery.
- Procurement Policy;
- Concerns and Complaints Policy;
- Whistleblowing Policy;
- SCR and Safer Recruitment Policy;
- Child Protection and Safeguarding Policy;
- Code of Conduct;
- Supplier terms and conditions.
In addition, we work closely with the National Joint Committee (NJC) to help reduce risk by improving working and pay practices.
Our Remuneration Committee has oversight of the process and practices embedded within E-ACT to reduce Modern Slavery and in ensuring our supply chains which rely on people can demonstrate adherence with local and national laws and regulations, including paying the minimum wage. The members of the Committee will work together with the Personnel Committee as appropriate on these areas.
Identifying and addressing risks
There are two main avenues by which modern slavery could impact E-ACT. The first is through safeguarding practices which covers child sex exploitation or human trafficking which can directly impact our pupils. This also potentially affects the staff of our contractors. The second is our supply chain and the vendors we contract.
E-ACT’s procurement regulations set out the requirements we have in relation to our engagement with suppliers. Our suppliers are expected to comply with all local and national laws and regulations. This includes paying their staff the minimum wage, and any on-site staff passing a DBS check. We publish our standard terms and conditions to ensure providers looking to contract with us are aware of our standards. Should suppliers fail to meet our minimum requirements, or be unwilling to make any changes, we may cease to trade with them.
Procurement is subject to internal audit review, as well as assessed by our external auditors annually. We are moving towards the predominance of contracts being appointed via frameworks which meet the requirements of the Modern Slavery Act 2015. In addition, we are utilising tenders across the business with a requirement for Modern Slavery Reporting should the bidders meet the reporting threshold.
In the previous year, we undertook a desk-based audit of our key supplier statements to identify any areas of risk to the business. No areas of risk were identified; however, we accept more can be done to fully understand our key suppliers supply chains. This will be a focus for the current year and will include supplier due diligence in the form of a self-audit.
We take safeguarding incredibly seriously. We have specific Safeguarding Regional System Leaders in every region, as well as Designated Safeguarding Leaders in every academy who lead on the implementation of policy and practice. They are incredibly experienced in this area and model excellent practice for all staff. Through their encouragement, each academy proactively works with the local authorities, the LADO and local stakeholders to combat all safeguarding issues, including child sex exploitation and human trafficking. Their good practice is shared amongst the regions. Safeguarding practice is reviewed on site at every Governance Review Day and a regional overview is provided to the Executive at the Regional Performance Board.
Statutory safeguarding practices and their impact on keeping children safe are audited via peer review regionally and specifically through the work of Internal Audit team.
Safeguarding is an agenda item at every Education Committee and every full Board meeting. We have a named safeguarding representative on the Board who sits on both the Education Committee and Personnel Committee.
Our Child Protection and Safeguarding Policy is reviewed annually by the Executive Leadership Team and the Board and is fully compliant with the DfE, Keeping Children Safe in Education 2019. Due to the geographical spread of our academies, each site is required to understand its local safeguarding context and this is included with the policy for each academy site.
Every member of staff, whether or not they are based in an academy, is trained on the policy (either in person or via e-learning) and is required to declare annually that they have read and understood the same. In addition, E-ACT also has a Whistleblowing Policy which enables those with concerns about any wrongdoing or breaches of law, to raise these concerns in confidence without fear of disciplinary action.
The focus within the safeguarding training is on early identification of those at risk of exploitation.
We are satisfied that through our robust safeguarding training that staff could identify and act appropriately for at risk pupils, staff and contractors.
This is not an area for complacency however, and options will be reviewed in year to identify any further training that can enhance the knowledge of our staff.
We will also review our process for raising concerns to ensure that there are clearly signposted avenues to report concerns of whistleblowing or modern slavery which are available to all users of our estates.
To date, no referrals have been made in relation to modern slavery or child sex exploitation.
Signed: Jane Millward, CEO and Accounting Officer for E-ACT
Dated: 11 February 2020
Approved by the Board of Trustees on the 11 day of February 2020