E-ACT Modern Slavery Statement 2018-19
This statement is made on behalf of the E-ACT Multi-Academy Trust 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 2018 August 2019.
E-ACT recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely 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 own business and its supply chains.
We recognise that as a national provider of education which works within some of the most economically deprived areas of the country, 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. The second is our supply chain and the vendors we contract.
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.
We take safeguarding incredibly seriously. 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.
We have specific safeguarding leads in every region 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. In addition to the regional leads, we also have a safeguarding lead in every E-ACT academy.
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 Audit and Risk Committee and Finance Committee.
Our safeguarding policy is reviewed annually by the board and is fully compliant with KCSIE. 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 on each academy site.
In addition to the above, E-ACT also has mandatory safeguarding e-learning modules and a Whistleblowing Policy which enables those with concerns about any wrongdoing or breaches of law these concerns can be raised in confidence without fear of disciplinary action.
Our processes are audited via peer review regionally, and specifically via our Internal Audit team.
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 live up to our expectations 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.
Our suppliers are made up of both national chains and local contractors, we do not contract outside of the United Kingdom. We have not identified any key risk suppliers in our supply chains.
We acknowledge that we could do more to instil mindfulness of modern slavery in our suppliers and we will be working on this element during the coming financial year, especially in relation to local suppliers which may not be subject to the reporting requirements of the Act.
Problems we have faced
In the last financial year, our Midlands region initially reported low acceptance rates for safeguarding referrals to the local authority. This was an area of significant concern for the trustees, as well as the national and regional teams.
Work was undertaken to identify the cause of this worrying trend and it was identified that the cause was a reporting error due to the differences in reporting systems for one local authority. This reporting difference has now been rectified and safeguarding referral acceptance is now in line with other regions when measured on a like for like basis.
In addition to the referral difficulties, two major safeguarding instances occurred within the region and E-ACT met and worked with the local authorities to put systems in place to highlight the safeguarding concerns felt by colleagues involved.
Our next steps
Our key lines of improvement will be focused on increasing the robustness of our procurement practices.
- Continue to reinforce strong standards of safeguarding practice
- Requirements around compliance with the Act will be inserted into all non-framework tender documents
- A purpose statement to be developed for our contractors to sign-up to, this will be particularly relevant for local contractors and will encourage compliance with the spirit of the Act
- Develop a concerns process for contractors which is outside of their usual reporting requirements and would enable to them to flag untoward process to us should it be appropriate
Statement approved by the Board of Trustees 27 February 2019.
Signed: David Moran (Accounting Officer)
Date: 27 February 2019