Modern Slavery

Modern Slavery Act 2015: Slavery and Human Trafficking Statement

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

The Modern Slavery Act 2015 introduced changes in UK law focused on increasing transparency in supply chains. Specifically, large businesses are required to disclose the steps they have taken to ensure their business and supply chains are free from modern slavery.

CATS Global Schools recognises that it has a responsibility to take a robust approach to slavery and human trafficking. This statement sets out the steps we have taken and continue to take to ensure that slavery and human trafficking are not taking place in any of our supply chains or businesses and is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Organisational structure and supply chains

CATS Global Schools is a provider of higher education, professional education and learning services. CATS Global Schools currently operates in the UK, USA and China and has a presence in several other countries.

CATS Global Schools Group includes the following companies within its modern slavery statement for the above period:

• CGS Administration Services Limited
• CATS Colleges Holdings Limited
• Stafford House School of English Limited
• Cambridge Arts & Sciences (trading as CSVPA and CATS Cambridge)
• CATS Canterbury Limited (trading as The Worthgate School)
• CATS College London Limited (trading as Guildhouse School, London)

CATS Global Schools does not have complicated supply chains with many levels, or suppliers with numerous sub-contractors, however, we do work with a wide range of suppliers and partners, some of which rely on agencies to supply both temporary and permanent staff. By the nature of these businesses, some of our suppliers are potentially at a higher risk than others and as such, we use a detailed category management system to ensure management practices are maintained when tendering for goods and services. Our master categories include Facilities Management, Professional Services, IT, Marketing, Print & Stationery, Estates Management, Subscriptions, Travel and Utilities.

When recruiting staff, we only use specified reputable employment agencies to source labour and seek information from the agency before accepting individuals from them.

Our Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations

• Whistleblowing policy We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential disclosure form.
• Employee code of conduct Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Recruitment policy We use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
• Any other policies relevant to our business or sector We may have other relevant policies to which they can refer, for example a corporate social responsibility policy, which should be accompanied by the steps taken to implement the policy and any examples where it has been used to address slavery and human trafficking risks.
  
  

Due diligence

CATS Global Schools undertakes due diligence prior to appointing new suppliers and regularly reviews its existing suppliers. Our due diligence exercise includes a ‘New Supplier Approval’ process which assesses suitability against our requirements. New suppliers are required to accept standard terms and conditions of trading to comply with all applicable anti-slavery and human trafficking laws.

Supplier adherence to our values

We have zero tolerance for slavery and human trafficking. We continue to review our supply chain management processes to ensure all those in our supply chain comply with our values and their legal obligations. This includes seeking confirmation from existing key suppliers that they have implemented contractual arrangements which prohibit modern slavery and trafficking and seeking confirmation that they have adopted their own anti-slavery and human trafficking policies.

Performance indicators

We have reviewed our key performance indicators (KPIs). As a result, we are:

• requiring all staff working in purchasing, Operations and Human resources (together with SLT and Executive members) to have completed training on modern slavery.
• we will include a section in the questionnaire—applicable to both existing and new suppliers—requesting confirmation that they have implemented contractual arrangements prohibiting modern slavery and human trafficking, and that they have adopted their own relevant policies.
  
  

Training: To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we require relevant staff to complete a Modern Slavery training module through our programme provider iHASCO and the National College. Modern Slavery training is compulsory for all new starters to complete this training within three months.

Approval

This statement was approved on 01/09/2025 by our board of directors who review and update it annually.