Introduction
ATL is a training provider offering further education and apprenticeships;
ATL employs approximately 70 staff members and teaches approximately 1500 students and apprentices;
ATL purchases approximately £2.4 million per annum of goods, services and works through various supply chain arrangements;
ATL is committed to employing staff, engaging with and supporting our students, acquiring goods, services and works for its requirements, and otherwise conducting its business without causing harm to others;
In so doing, we are committed to supporting the UK Government’s Action Plan to implement the UN Guiding Principles on Business and Human Rights and has built due diligence checks into the ATL’s Procurement processes.
Identified risks and steps being taken
ATL has identified the following areas of processing activities which may attract risk associated with modern day slavery and human trafficking:-
i) In its supply chains;
ii) Through use of agency or temporary staff;
iii) Through staff recruitment; and
iv) Students.
Supply chain
ATL’s supply chain has been identified as the area of the highest potential risk in terms of possible breaches to the Slavery and Human Trafficking Act. In order to mitigate this risk, ATL has implemented the following:
To ensure that slavery and human trafficking are not present in the supply chain during procurement procedures, we make all reasonable checks on suppliers’ compliance with ethical standards.
The following procurement categories have been identified as higher risk in terms of finding modern slavery and human trafficking occurrences in the supply chain:
- ICT Equipment and Services
- Administration & Facilities Goods and Services
- Cleaning Services
When procuring goods, works and services in the higher risk categories ATL makes enquiries of suppliers to prove a higher level of corporate social responsibility during the selection process.
Any and all organisations entering into or participating in an ongoing sub-contracting arrangement with ATL (otherwise known as a ‘Key Partnership’ agreement) will be provided with a copy of this policy statement and required to adhere to the same standards and principles. This will be monitored via due diligence activities; sub-contractors are advised to include a similar commitment within their own policy suites to ensure compliance.
Employment of staff through recruitment agencies and other sources
ATL recognises that a further high risk area of modern slavery is the use of temporary staff recruited indirectly by ATL through supply agencies or recruitment agencies.
When ATL requires the services of temporary staff, these staff are only sourced through established and accredited companies who can provide ATL with assurances that they comply with the requirements of legislation.
Direct employment of staff
Although ATL recognises that the risk level is lower in respect of staff it directly recruits, ATL has robust policies and procedures in place in respect of Safer Recruitment in Education. ATL is confident that this reduces the minimal risk of the occurrence of modern slavery by strict adherence to the ATL’s recruitment and candidate selection policies. In addition, ATL has a whistle blowing policy through which staff can raise concerns.
Students
Finally, although we acknowledge that the risk of students experiencing occurrences of modern slavery or human trafficking are extremely low, ATL does appreciate that whilst living within the South West, students may become aware of or become entrapped into the lifestyle of a modern slave.
ATL has in place easily accessible and well known channels through its safeguarding and learner support facilities through which students can obtain assistance, support and advice on their wellbeing.
This Statement has been approved by the Managing Director and published by the ATL. This statement will be reviewed every three years in accordance with the ATL’s review procedures.
Queries relating to this statement should be directed in the first instance to the Safeguarding Team: