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Modern (Anti) Slavery Policy

MODERN (ANTI) SLAVERY POLICY

1. POLICY AIM
a. 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.
b. The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in the Company’s business or in any of the Company’s supply chains.
c. The Company is also committed to ensuring there is transparency in its business and in its approach to tackling modern slavery throughout the Company’s supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015.

2. POLICY SCOPE
a. The Company expects the same high standards from all of its employees, consultants, agents, clients, suppliers, stakeholders and other business partners, and as part of the Company’s engagement, contracting and procurement processes.
b. The Company prohibits the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and it is expected that the Company’s suppliers and clients will hold their own suppliers to the same high standards.
c. This policy applies to all persons working for the Company or on the Company’s behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
d. This Modern (Anti) Slavery Policy and Statement is intended and will be applied in all countries in which the Company operates.

3. RESPONSIBILITY FOR THE POLICY
a. The Company has overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations, and that all those under its control comply with it.
b. The Company has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
c. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
d. Employees, consultants, agents, clients and suppliers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Company CEO.

4. COMPLIANCE WITH THE POLICY
a. Employees, consultants, agents, clients and suppliers must ensure that they have read, understand and comply with this policy.
b. The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains is the responsibility of all those working for the Company or under the Company’s control.
c. Employees, consultants, agents, clients and suppliers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
d. Employees, consultants, agents, clients and suppliers must notify the Company CEO as soon as possible if it is believed or suspected that a conflict with this policy has occurred or may occur in the future.
e. Employees, consultants, agents, clients and suppliers are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the Company’s business or supply chains of any supplier tier at the earliest possible stage.
f. If it is believed or suspected that a breach of this policy has occurred or that it may occur, report it in accordance with this policy or the Whistleblowing Policy as soon as possible.
g. It should be noted that where appropriate, and with the welfare and safety of local workers as a priority, the Company will give support and guidance to its suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
h. If there is any doubt as to whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Company’s supply chains constitutes any of the various forms of modern slavery, raise it with the CEO.
i. The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
j. In line with the Whistleblowing Policy, the Company is committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the Company’s business or in any of the Company’s supply chains.
k. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.
l. If it is believed that anyone has suffered any such treatment because of raising concerns under this policy, they should inform the Company CEO.
m. For employees – if the matter is not remedied, they should raise it formally using the Company’s Grievance Procedure, which can be found in the current employee handbook.

5. COMMUNICATION & AWARENESS OF THIS POLICY
a. Training on this policy, and on the risk the Company business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for the Company, and updates will be provided using established methods of communication.
b. The Company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of the Company’s business relationship with them and reinforced as appropriate thereafter.

6. BREACHES OF THIS POLICY
a. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
b. We may terminate the Company’s relationship with other individuals and organisations working on the Company’s behalf if they breach this policy.

7. POLICY CHANGES
a. This policy does not form part of an individual’s contract of employment and may be amended from time to time.

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More About Ellen

Ellen is a highly experienced professional in the field of equality, diversity, and inclusion (EDI), with a career spanning over 20 years both in the UK and internationally. Her work covers all areas of EDI and she has specific expertise in disability and gender equality within the higher education sector. Throughout her career, Ellen has worked on numerous initiatives to make higher education more inclusive and accessible for diverse groups of students and staff.

Ellen’s work with UK Research and Innovation (UKRI), which invests approximately £380 million annually in studentship grants, has focused on ensuring that its terms and conditions are inclusive for students from a variety of backgrounds. She has also contributed her expertise as a member of the Equality and Diversity Advisory Panel for the Research Excellence Framework (REF) for both the 2014 and 2021 assessments, working to ensure that equality and diversity considerations are central in the distribution of nearly £2 billion per year in research funding.

Ellen has also held significant roles at Advance HE as a Senior Consultant, where she advised the Disabled Students Commission, and at the Equality Challenge Unit (ECU) as a Policy Manager. She has been deeply involved in initiatives such as addressing gender pay gaps, tackling sexual harassment, advancing the Athena Swan Charter for gender equality, improving the experiences of transgender staff and students and students during pregnancy and maternity. She has also developed guidance on equality and employment law. Notably, her involvement in the development of the Codes of Practice on the Equality Act 2010 .

Internationally, Ellen served on the advisory board for the EU-funded Genovate project and led gender equality and social inclusion efforts for the UKAID Skills for Prosperity program. This initiative supported TVET and higher education projects in nine middle-income countries. Before her time at ECU, Ellen held the position of Policy Director at a disability rights and education charity, and she has a background in international human rights advocacy and policy.

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More About Sara

With a rich career spanning retail, education, and national skills development, Sara is an expert in forging meaningful partnerships between the public and private sectors to build lasting, sustainable futures. Having worked from shop floor to boardroom, she brings a deep understanding of the challenges businesses face in developing skills, driving inclusion, and embedding sustainability at the heart of their strategy.
Sara’s passion is making sustainability accessible, understandable, and actionable. As the Co-Founder of The Sustainability Academy, she specialises in embedding the United Nations Sustainable Development Goals (SDGs) into businesses of all sizes, both in the UK and internationally. Her work ensures that sustainability becomes more than a policy—it becomes part of the culture, empowering employees at every level to make meaningful change.
Sara has successfully designed and embedded sustainability training in a wide range of sectors and supports businesses to align global frameworks, such as Vision 2030 in Saudi Arabia, into practical, measurable strategies that support people, planet, and purpose.

Key Skills:

  • Building public-private partnerships that drive real business impact
  • Expertise in sustainable futures using the SDGs as a global framework
  • Making complex sustainability goals simple and actionable
  • Embedding sustainability into company culture, from boardroom to shop floor
  • Specialist in ESG strategy, inclusion, well-being, and social impact
  • Proven track record in talent development and skills growth across sectors

 

Why Work With Sara:

Global expertise with local, tailored solutions SDG-led, making sustainability relevant to any sector Focus on people-first strategies for lasting cultural change. Access to a global network of partners and experts and a hands-on approach from strategy through to implementation.

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More About Tracy

Tracy Duggan is a professionally qualified executive coach and mentor with over 25 years of expertise in the public, private, and third sectors.

She has held strategic roles that have shaped regional economic strategies and supported global brands with organisational growth and development. As a key team member for major initiatives like the UK Commission for Employment and Skills and the National Skills Academy for Retail, Tracy has the ability to forge strong stakeholder relationships, facilitate impactful discussions, and design win-win solutions.

Her experience covers organisational development, leadership and team coaching and mentoring, sustainability, and employee wellbeing.

As a licensed Investors in People (IIP) practitioner, Tracy supports organisations of all sizes in aligning their people strategies with business objectives across various industries.

Through her own consultancy Skillslocal, she developed the flourish® framework and step up and standout programme®. Supporting businesses to integrate leadership skills, social impact, sustainability, and wellbeing into their operations. The Flourish® framework encourages organisations to introduce sustainable people practices whilst empowering leaders and teams. This helps maximise results for organisations and businesses to thrive through their people with passion and purpose.

Key Skills:

  • Strategic planning and stakeholder engagement at local, regional, and national levels.
  • Development and execution of national and international skills programmes
  • Expert in people development, wellbeing, and psychological safety.
  • Leadership, team and group coaching and mentoring and development of tailored programmes that businesses growth.
  • Building long-term partnerships that drive transformational change.

 

Why Work With Tracy:

  • Has a genuine passion for empowering people and businesses to thrive.
  • Delivers bespoke, actionable solutions that go beyond theory.
  • Brings deep cross-sector insights to address unique business challenges effectively and efficiently.
  • Has a proven track record of developing, implementing and transforming strategic frameworks into real-world successes.
  • Provides access to a trusted network of partners and experts cultivated over three decades.
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More About Lisa

Lisa is a solution focused and highly professional international TVET consultant, with more than 20 years’ experience in governance of TVET systems, development of skills value chains, employer engagement in design, development and delivery of occupational standards and qualifications, in the UK and internationally.

Lisa has worked with UNESCO, the EU, the British Council, the UK Government, overseas Ministries of Education and the Crown Prince’s Foundation (Jordan) in enhancing TVET in the Middle East, North Africa and Sub-Saharan Africa (SSA). Designing, developing and delivering TVET programmes and activities that strengthen the quality and standard of existing TVET systems, ensure international recognition, closer alignment to the labour market and industry requirements and promote partnership and collaborative working with key stakeholders.

Lisa is passionate about improving the quality of TVET and enhancing employability. The success of her work is down to her capacity to build relationships that encourage collaboration, include all stakeholders and focus on developing tailored solutions that are sensitive to the respective contexts.

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More About Gary

Gary is an inclusion and education expert with over 20 years of experience in leading, developing and delivering diversity and inclusion practices in the global context in the higher education, research and international development sectors. He is based part of year in the UK and part of the year in Singapore.

He has extensive experience providing technical assistance on inclusion, including being the the lead technical adviser for gender equality and social inclusion for the UK Government’s Skills for Prosperity programme in 9 countries. He has delivered numerous projects for the British Council, including the development of a gender and equality strategy for the British Council East Asia Going Global Partnerships Programme across 12 countries.

He has also been involved in numerous projects across Europe, including work for Eurydice, the European Commission network of national education ministries. Gary was previously the Director of Knowledge, Innovation and Delivery at Advance HE, a global higher education development organisation. Prior to that, he was Deputy Chief Executive at Equality Challenge Unit, the UK’s higher education equality and diversity agency.

Gary has served on a number of external advisory boards, including being a member (from 2014 to 2022) of the Gender Equality Commission of the Swiss National Science Foundation, the main research funding agency of Switzerland. He is currently an external adviser to Coventry University’s Centre for Global Learning.

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More About Elisa

Elisa Lavore Fanjul is an international consultant with 15 years of experience in social innovation, specializing in gender equality and social inclusion in education and workforce development. She has worked extensively with international organizations, governments, and academic institutions to design, implement, and evaluate programs that promote equal opportunities for youth, women, and vulnerable populations.
Throughout her career, Elisa has led gender-focused initiatives across Latin America, including her role at Development Alternatives Inc., where she spearheaded the gender equality and social inclusion (GESI) strategy for the UK’s Skills for Prosperity Mexico program. She provided technical assistance to educational institutions, trained over 1,000 stakeholders on gender-based violence prevention, and developed interventions to challenge gender stereotypes in career choices.

At the Inter-American Development Bank (IDB), she has been instrumental in shaping policies that integrate gender perspectives into education and workforce initiatives, including the Strengthening Technical Capacities in the Agricultural Sector project and the Dual Education Model Adoption study in Oaxaca. Elisa also collaborated with the Workforce Development Trust to assess and advance British Council’s gender equality in STEM education in Brazil and Mexico.

Her expertise extends to youth empowerment and adolescent development, as demonstrated in her work with UNICEF Mexico, where she managed life and work skills programs, digital education initiatives for indigenous youth, and projects addressing gender-based barriers in education and employment.
Elisa holds a Master of Arts in International Comparative Education from Stanford University and a Bachelor’s degree in Political Science from the Mexico Autonomous Institute of Technology (ITAM). Fluent in Spanish, English, and French, she continues to drive inclusive, evidence-based solutions that create lasting social impact.

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More About Karen

Karen holds a PhD in Sociology, a Master’s degree in Contemporary Latin American Studies and training in Psychology, with over six years of experience in applying qualitative social research methodologies. Her focus has been on direct work with communities and key stakeholders in the field, which has allowed her to comprehensively address crucial societal issues.

Throughout her career, she has led diagnostic assessments, formulated and implemented public policies and designed programmes and strategies aimed at promoting gender equality and social inclusion, in both rural and urban contexts. Her work spans areas such as the prevention of gender-based violence, the promotion of wage equality, the design of strategies for the inclusion and labour equality of women and the advancement of their economic autonomy from an intersectional perspective. Additionally, she has closely collaborated with the public, private and academic sectors to generate sustainable and effective impacts.

She stands out for her strategic thinking, assertive communication, teamwork capabilities, innovation, creativity and transformational leadership. She is deeply committed to generating practical solutions with tangible results in her projects, leveraging both her academic background and professional experience.

Her continuous willingness to learn and her collaborative approach enables her to effectively tackle challenges, consistently achieving the established objectives. Currently, she is  complementing her training with a Master’s in Business Intelligence, which has allowed her to develop a hybrid methodological approach, integrating both qualitative and quantitative tools to address social issues from a holistic and effective perspective.

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More About Mark

Mark is a dynamic and committed associate consultant specialising in leadership and management development and the design and delivery of impactful training programmes, with a strong focus on UK and global skills development aligned to TVET. Following a distinguished 23-year career in the Royal Artillery, where he gained exceptional leadership, planning, and adaptability skills in high-pressure and dynamic environments, Mark transitioned into a 15-year career in Further Education.

During this time, Mark has focused on creating and delivering training solutions that achieve measurable outcomes. He successfully led the £4.8 million Local Skills Improvement Fund (LSIF) project in West London, managed Skills Injection Fund projects, and developed workforce strategies to build high-performing teams that support organisational success.

Mark’s expertise spans developing strategic partnerships, business development, stakeholder engagement, and curriculum development across a range of sectors, including engineering, construction, health, and digital. He has significant experience in capacity building for Higher Technical Qualifications (HTQs) and apprenticeships, ensuring alignment with education and industry needs to support sustainable workforce and skills development.

With a commitment to global TVET advancement, Mark has collaborated with UK and international partners to address skills gaps and deliver solutions that strengthen economic resilience and workforce adaptability. As an associate member of the UK Skills Partnership, Mark contributes to driving skills solutions that address both national and global priorities.

As an associate consultant for Skills for Inclusion, Mark will leverage his extensive experience to support the delivery of bespoke skills solutions, ensuring inclusivity and alignment with employer needs. Drawing on insights from Further Education, Institutes of Technology (IoTs), and the UK Skills Partnership, he will contribute to improving workplace inclusivity and productivity through strategic partnerships, tailored training programmes, and workforce development initiatives.

Mark combines his military and educational experience to deliver exceptional results for clients. His collaboration with Skills for Inclusion reflects his dedication to fostering impactful, inclusive solutions across diverse sectors, reinforcing his commitment to addressing global skills challenges and advancing TVET excellence.

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More About Edward

Edward is an international consultant based in Mexico City with extensive experience in Technical and Vocational Education and Training (TVET), skills development and inclusion in the workplace. He has worked across Latin America and the Caribbean, leading projects that strengthen workforce development, bridge education and industry and promote equitable access to skills training.

He has collaborated with governments, international organisations and higher education institutions (HEIs) to design labour market-aligned skills strategies, enhance work-based learning programms, and develop inclusive policies. His expertise spans TVET reform, sustainable skills ecosystems, microcredentials and gender equality in STEM. His recent work includes leading inclusive labour market initiatives in HEI systems in Brazil, Mexico and Peru, supporting the eco-tourism transition in Belize through a skills development strategy and designing work-based learning models for TVET institutions in Mexico and Colombia. He has also contributed to sector skills council development in Jamaica, supporting skills alignment in key industries such as logistics, agribusiness and manufacturing.

He continues to advise on policy development, capacity-building and workforce innovation, ensuring that TVET and HE systems across the region are responsive to industry needs and inclusive of underrepresented groups.

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Jayne Norman: Inclusive Skills Specialist

With her expertise in TVET/adult curriculum development and training, Jayne has made significant contributions to various projects and initiatives in the field of vocational education with a lens on diversity, equity and inclusion.

Bio

Jayne is an expert in the development of Technical and Vocational Education and Training (TVET), adult learning and adult language and literacy curricula, with extensive national and international capacity-building experience for TVET/adult education/training and educators.

Her work includes developing competency-based curricula development and support, as well as providing training for teachers and trainers in various TVET and adult learning programs, including international apprenticeships, traineeships, and learning and assessment frameworks. Jayne is passionate about and is highly skilled in embedding transferable/employability/core skills into curricula, helping to close skills gaps to create demand-led curricula and learning programmes from pre-employment to master’s degree level.

She is a Diversity, Equity, and Inclusion (DEI) pioneer who specialises in developing guidance and learning in this area. This includes digital handbooks for education institutes, learners, employers (including C-Suite, management, and HR professionals) as well as creating and delivering DEI training up to stakeholder level.

Jayne has a proactive and positive attitude to curricula design and delivery, thinks logically and laterally in design and possesses excellent communication and core skills, making her an accomplished humanitarian technical author and trainer.

Qualifications, skills and certificates

  • BA (Hons.) Modern European Studies
  • Cert ADDS in Adult Dyslexia
  • City & Guilds 7307 Stage 2 in Teaching Adult Learners
  • Teaching English to Speakers of Other Languages
  • UNDSS BSAFE Certificate
  • Certificate in Virtual Training Delivery

Professional Experience

As a Master Trainer and Technical Author, Jayne has been involved in various significant projects across different sectors. Some notable experiences include:

  • Creating an online toolkit and action plan on behalf of EBRD for HR professional and private sector C-Suite executives/managers for promoting employer-supported care solutions for working caregivers. 
  • Developing mainstreamed and embedded Core Skills/employability programmes for the garment/textile (for young women) and agro-processing sectors in Ethiopia on behalf of ILO. Building capacity in country as Master Trainer of Training of Trainers
  • As part of EBRD’s Economic Inclusion Strategy – developing and building capacity for educators of new training programmes in Lithuania and Latvia for Akropolis retail, with a primary focus on the inclusion of the older workforce (age 50+) as well as people with disabilities where country level inclusion gaps are largest. Technical author of HR Handbook focusing on inclusive recruitment, reward and retention of older workers and training on best practices for management of multi-generational teams.
  • Technical Authoring of a Gender Equality and Social Inclusion toolkit for HR professionals and managers with HR responsibility for construction businesses in Colombia on behalf of Skills for Prosperity Colombia.
  • Technical Authoring and capacity building coaching workshops for Skills Development Fund partners in Palestine on behalf of ENABEL. Coaching workshop subjects:
    • Successful Public Private Partnerships
    • Quality Assurance of Public Private Partnerships
    • Supporting Trainees on Pilot Programs
    • Gender Equality and Social Inclusion
    • Using Labor Market Intelligence
  • Technical Authoring of “Delivering the Toolkit for Tourism Recovery – Sri Lanka” A Professional Development Programme. Virtual capacity building with educators. Technical Authoring on guidance on Gender Equality and inclusive provision of skills training, on behalf of the Government of Sri Lanka
  • Technical Authoring and capacity building Work Based Learning Adult Education toolkits and workshops, including DEI. Training university education staff in international best practice, on behalf of Skills for Prosperity Mexico. Technical author of a series of GESI handbooks for students, university management and placement/internship employers on inclusive internships and placements.
  • Development of extensive Women’s Enterprise qualification in collaboration with Lynne Franks OBE: “SEED – The empowerment tool for the advancement of the 21st century woman”
  • Technical Author of ESOL embedded Information Communication Technology programme for Asian Women (Tribal/Newham Council, London UK) for Tribal Education
  • Serving as a Technical Author and Master Trainer for COVID-19 Compliance, specifically for hospitality and tourism businesses reopening after quarantine in Jordan.
  • Contributing as a Co-Technical Author (Life Skills and English for Hospitality) for the Youth Career Initiative, on behalf of The International Tourism Partnership.
  • Authoring a hospitality casual events staff prevocational training program with Jordan Hotel Association for Jordan.
  • Conducting Master Trainer sessions on TVET and competency-based curriculum and assessment design across sectors with The British Council in Uzbekistan and Ghana.
  • Providing training on TVET assessment design and training of master trainers for the construction sector in the Philippines.
  • Leading as the Technical Author for an extensive Tourism Training and Licensing program for new tourist guides in Abu Dhabi in association with the Abu Dhabi Department of Culture and Tourism.
  • Developing training programs for new recruits in the hospitality and customer service sectors for the new Ayla eco-resort in Aqaba, Jordan.
  • Creating hospitality apprenticeship specialisms for Azerbaijan, specifically in front of House, housekeeping, and commis chef roles, mapped to new UK apprenticeship standards.

Jayne has also worked as a Membership Programme Manager for the National Skills Academy for Retail, delivering induction sessions for new skills shops and providing training in various products and services. Additionally, she held the role of Adult Language Literacy and Numeracy Manager at Skillsmart Retail, where she commissioned an action plan on Language, Literacy, and Numeracy needs in the retail sector and worked with employers and stakeholders to set up Adult Language, Literacy, and Numeracy workplace provision.

Testimonial

We meet many people in our lives whose names we can’t even recall as years pass by. Only rarely we meet people that leave a trace in our hearts. Jayne Norman is a person to remember. She leaves a legacy in a person’s, people’s, a country’s life by sharing her professional expertise, as well as embracing people she meets with her positive aura and kind spirit. This has been a productive week of teacher training, as well as human relations that we shall remember for a long time!

Nargiz Huseynova Country Director, British Council Azerbaijan, Wider Europe 

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More About John

John is a TVET sector expert with extensive experience of contributing to international development projects including in Nepal, Tanzania, Jordan, South Africa, Rwanda, West Bank and Gaza, India, Kosovo, Pakistan, and Sudan, funded by FCDO, EU, KfW, Swisscontact, GIZ, USAID and EBRD. He has extensive experience in providing policy input to national TVET sector strategic initiatives, conducting sector needs assessments, promoting inclusion and access, establishing sustainable TVET models, and leading capacity development interventions.

John has a professional background of over 20 years in the UK’s Further Education College (TVET) sector including working as the International Director for England’s national college agency, the Association of Colleges. He has also held senior roles in the UK’s Sector Skills Council and Higher Education sectors. He has significant experience of leading teams and working effectively with senior stakeholders, including as an EUD project Team Leader.

John has particular interest in establishing strong public private partnerships that provide sustainable platforms for employer input into quality and relevant TVET models. He has published skills sector reports and holds post-graduate qualifications in education development. John has been utilising his professional experience as a skills sector consultant since 2018.

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