Modern Slavery Policy

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1. Definition and purpose of this policy

This document sets out the policy and procedures of Learn Amp against Modern Slavery.

Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or 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.

This document sets out the policy of Learn Amp with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers.

2. Statement of intent and steps to prevent modern slavery

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and we are evolving and updating our contracting processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We require our suppliers to hold their own suppliers to the same high standards.

Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. In view of this we intend to implement the following measure:

1. a) conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas;
2. b) to review and consider the risk when taking on a new supplier as part of a screening process; and
3. d) seek confirmation in writing of key and regular suppliers of their adherence to the Act.
   

3. Reporting any suspected modern slavery

Employees are encouraged to raise any concerns about suspected modern slavery associated with the company or our suppliers and should do this either through their line manager or direct to the CEO.

Members of the public or people not employed by Learn Amp can write, in confidence, to the CEO at our main office or to the registered office to raise any concern, issue or suspicion of modern slavery in any part of our business or related supply chain.

We aim 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. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

Learn Amp will accept and take seriously concerns communicated anonymously. However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.

4. Responsibilities and review

Ultimate responsibility for the prevention of modern slavery rests with Learn Amp’s leadership team. The CEO and directors have overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

Managers 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.

The directors will review this policy from time to time as they determine appropriate.