Education Development Trust ("the Company") is a UK charity and company limited by guarantee, operating around the world providing services in the field of education in accordance with its charitable objectives. It has a number of subsidiary companies and branch offices in a number of countries, and works with many organisations and governments in order to further its aims. The Company's business model is mainly based on bidding for high value contracts and providing services such as training, inspections, educational reform and consultancy services across the globe. As such the Company has a large number of suppliers of goods and services, as well as a great many subcontractors and partners from numerous consortia each of which will have their own subcontractors, affiliates and associate entities. The Company therefore is connected to multiple entities through numerous contractual relationships across many countries. The Company recognises that in some of these countries approaches to matters such as human rights and the treatment of local and immigrant workers may vary, and that organisations with which the Company works may utilise practices, unbeknownst to the Company, that would be contrary to the provisions and spirit of the Act.
In view of this, the Company recognises that there could be a risk of human trafficking, as defined by the Act, occurring within its extensive and complicated supply chain even if the Company itself has no knowledge or could not reasonably be expected to have any knowledge of any specific incidences of human trafficking or slavery occurring. The Company is therefore committed to mitigating that risk insofar as it is able to do so in pursuit of achieving its mission to provide evidence-based sustainable solutions that transform lives through education.
The Company has an Anti-Slavery Policy in force across the organisation, which is communicated to all branches of the Company and its subsidiaries around the world. All members of staff are provided with the Policy as part of their induction and initial training on commencement of employment and are expected to be familiar with and to follow the Policy. Each year, the Policy is updated in line with any new guidance on the Act and its requirements and is communicated in a Company-wide notification to all employees. Where a risk is identified in a particular area, advice and if necessary training is provided to the relevant team as and when required.
The Company reviews all draft contracts and all proposed new opportunities in overseas countries and the UK, with a view to considering any potential risk of human trafficking and slavery, and ensuring compliance as far as possible with any legislation relating to the same, (including where appropriate, proportionate and reasonable insisting upon adherence to its Policy and the Act) having regard to the legal, political and commercial reality of the territories and countries within which it works and the organisations in question. Where possible, due diligence is carried out in respect of organisations with which the Company partners and subcontracts specifically to evaluate the possibility of human trafficking and slavery within those organisations’ supply chains which might then impact the Company’s supply chain.
The Company's Policy requires it to maintain a record of all identified and potential risks of any slavery or human trafficking across its operations or those organisations with which it might be connected. This is considered each year and evaluated to identify areas of particular concern with a view to then addressing these concerns if possible, or enhancing due diligence or other review and intervention practices which may mitigate the identified risks. The intention is that in so doing, the Company may be able to identify areas of weakness and demonstrate an improvement year on year.
13th February 2019