Anti-Slavery Policy

Low Carbon Academy’s Mission Statement

Low Carbon Academy will inspire people to maximise their potential through learning

Your Ambition – Our Tradition

To achieve this Mission, the directors of NWSA are committed to the following strategic objectives.

We will: 

1. Proactively promote learning opportunities available at NWSA.
2. Strive to respond to the demands of individual learners, employees, employers and to national priorities by developing a wide range of flexible delivery options.
3. Constantly seek to improve and provide learning experiences of outstanding quality.

Purpose

In meeting with our obligation under Modern Slavery Act 2015, Low Carbon Academy offers the following statement as our contribution in the prevention of modern slavery.

Policy statement

Modern slavery can take various forms, such as, servitude, forced or compulsory labour and human trafficking. Low Carbon Academy has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity and transparency in all our business dealings and relationships. We are also committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our business or supply chains, consistent with our obligations under the Modern Slavery Act 2015. Low Carbon Academy expects the same high standards from all its suppliers, sub-contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery and expects that its suppliers will in turn hold their own suppliers to the same standards.

Identifying potential victims of modern slavery including human trafficking can be a challenge because the crime can manifest itself in many ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact they are using slave labour. However, Low Carbon Academy accepts that it has a responsibility through its due diligence processes to ensure that workers are not exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for Low Carbon Academy or on the Company’s behalf in any capacity, including employers, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

Scope

This policy is relevant to all internal and external relationships and communications with Low Carbon Academy

This policy covers:

NWSA employee responsibilities

The prevention, detection and reporting of modern slavery and human trafficking in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for Low Carbon Academy or under the Company’s control. You are required to avoid any activity that might lead to a breach of this policy.

Record-keeping

If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or report it immediately. You are encouraged to raise concerns about any issue or suspicion of modern slavery and human trafficking  in any part of Low Carbon Academy’s business or supply chains as soon as possible. If you are unsure about whether a particular act, the treatment of workers or their working conditions within any of Low Carbon Academy’s supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager.

You can view the Act on the government’s website https://www.gov.uk/government/collections/modern-slavery-bill or call the Modern Slavery Helpline on 08000121700 for further information and guidance on modern slavery.

Low Carbon Academy 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.  Low Carbon Academy is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

Training and communication

Regular training on this policy and on the risk that the business faces from modern slavery and human trafficking in its supply chains will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases. The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into the new or renewed contracts with them.

Who is responsible for the policy?

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The Senior Director has primary and day-to-day responsibility for implementing this policy, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.

Monitoring and review

Any employee who breaches this policy could face disciplinary action. Low Carbon Academy may terminate its commercial relationship with suppliers, sub-contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

We will continue to keep our staff informed and raise awareness of how to recognise and respond to indicators of human right abuses. We will adapt and promote our existing company policies to incorporate modern slavery and human trafficking issues including our whistleblowing policy which allows employees to report any concerns confidentially.

Responsibility for review : Samuel Riley Chief Executive Officer

Review Date: October 2022