Modern Slavery Act 2015: Slavery and Human Trafficking Statement
Financial Year: 1 April 2023 – 31 March 2024
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 todisclose 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.
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 Administrative Services Limited
CATS Colleges Holdings Limited
Stafford House Companies Limited
Stafford House School of English Limited
Stafford House Study Holidays Limited
CEG Colleges 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)
Our policies on human trafficking and slavery
CATS Global Schools has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships to implement and enforce appropriate and effective systems and controls, to ensure modern slavery is not taking place anywhere in our own business or in our supply chains. We currently operate the following policies that go to making our employees aware of what is and is not acceptable practice and to allow them to raise concerns where appropriate:
Whistleblowing policy: The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Employee code of conduct: The organisation’s code of conduct makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
Our supply chains
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.
Due diligence process for Slavery and Human Trafficking
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.
Planned activities for FY2023/24
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. Modern Slavery training is compulsory for all new starters to complete this training within three months.
Update relevant processes and policies, including an updated Procurement Policy, Procurement Guidance and a new Modern Slavery Policy, where applicable, to reflect changes in legislation and/or best practice.
Continue to ensure that modern slavery is addressed throughout the procurement process by applying enhanced due diligence and risk checks on significant contracts that evaluate potential suppliers in relation to modern slavery before they enter the supply chain.
This statement has been approved by the Board of CATS Global Schools on the 31 March 2023 and has been signed and dated by Christopher Stacey, Chief Executive Officer.