1. Introduction

The Training Brokers (TTB) are an independent training provider based in Salford. Annually, we service up to 300 learners and work with key stakeholders to deliver our courses. TTB’s Anti-Slavery and Human Trafficking Policy is organisation-wide and applies to anyone working for us, with us, or on our behalf in any capacity, including employees, contractors, consultants, agency workers, volunteers, and partners.

The policy set out below defines our absolute commitment to ensuring that modern slavery, servitude, forced labour, and human trafficking have no place in our organisation or our supply chains.

2. Policy Statement

TTB understands that modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour, and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a severe crime and a fundamental violation of human rights.

TTB operates a strict zero-tolerance approach to modern slavery in all its forms, both within our own operations and throughout our supply chains.

3. Our Commitments and Implementation

TTB will uphold and operationalise this policy by:

– Maintaining a zero-tolerance approach to modern slavery within our organisation, partner networks, and supply chains.

– Recognising that the prevention, detection, and reporting of modern slavery in any part of our organisation or supply chain is the collective responsibility of all those working for us or on our behalf. Workers must never engage in, facilitate, or fail to report any activity that might lead to, or suggest, a breach of this policy.

– Actively engaging with our stakeholders, educational partners, and suppliers to assess, identify, and address the risk of modern slavery in our operations and supply chains.

– Applying a risk-based approach to our procurement and contracting processes, keeping them under continuous review. We will incorporate specific anti-slavery and human trafficking provisions into contracts with third parties where appropriate, and require suppliers to comply with our Supplier Code of Conduct.

– Requiring, where appropriate under our risk assessment framework:

Employment and recruitment agencies, as well as other third parties supplying temporary or permanent workers to our organisation, to confirm adherence to our standards.
Suppliers engaging workers through sub-contractors or intermediaries to obtain formal agreement from those third parties to adhere to required conduct codes.

4. Risk Assessment and Due Diligence

As part of our ongoing corporate governance, risk assessment, and due diligence processes, we regularly evaluate our operational sectors and supply chains. Where warranted by risk levels, we reserve the right to carry out audits of suppliers and partners to verify compliance with our anti-slavery standards and Code of Conduct.

5. Reporting, Non-Compliance, and Enforcement

Reporting Concerns: Any employee, learner, or stakeholder who suspects or identifies any instance or risk of modern slavery within TTB or our supply chains must report it immediately to the Managing Director.

Breach of Policy: If we find that individuals, contractors, agencies, or organisations working with or on behalf of TTB have breached this policy, we will take swift and decisive action. This includes notifying the appropriate statutory authorities (such as the Gangmasters and Labour Abuse Authority or local law enforcement) and immediately terminating our commercial relationships.

6. Publication and Governance

Communication: This policy is published on our official website, included within staff and student handbooks, and displayed prominently on our organisational notice boards. It is also integrated into staff induction training.

Review: This policy is reviewed annually by the leadership team to ensure legislative compliance and operational effectiveness.

Responsibility: The Managing Director holds overall responsibility for the implementation, monitoring, and execution of this policy.