Modern Slavery Statement
Witherslack Group LTD Modern Slavery Statement - Year ended 31 March 2021
Witherslack Group is the leading provider of specialist education and related residential care for children and young people with social, emotional and mental health needs, communication difficulties and complex learning needs. We operate in a highly regulated environment with all establishments subject to regular inspection by Ofsted. In addition to the sector regulator we have regular internal and external quality assurance audits and inspections the outcomes of which are regularly reviewed at our Main Board
As an organisation that provides education and related care to some of the most vulnerable members of society we understand the importance of removing slavery and human trafficking from society. We are committed to implementing policies that aim to prevent this within our business and, to the best of our ability, within any supply chains that support us.
Witherslack Group is head quartered in Cumbria and has 56 establishments operating across England. We directly employ around 1800 permanent staff. The majority of our workforce are front line care, education & clinical staff supported by leadership and support functions.
We have identified the risk of modern slavery practices in our directly employed workforce as low. This is due to the highly regulated nature of our business. Almost all of our workforce are permanent employees who are recruited by our own in-house recruitment team. Once an employee has joined the business, their information is gathered and managed through a centralised HR platform.
Our recruitment and onboarding processes comply with the regulatory and safer recruitment guidelines for those working with children. From time to time we use supply agencies to cover short term absences in our schools. All supply agencies we choose to partner with are required to comply with the same statutory safeguarding checks. We understand that as these agencies are not directly part of our business, there is a risk that they may be in breach of modern slavery practices, without our knowing. From time to time we may have a very small percentage of our workforce hired on temporary contracts, these roles are normally professional service contracts. We do not employ seasonal or casual workers.
All employees are paid in excess of the National Minimum Wage. The vast majority of our employees are paid in accordance with National pay scales that are set by the UK government.
Employees are undertaking work in controlled environments where there are established policies and processes. All staff have access to our Employee Handbook when they join and it is also available online to allow everybody to easily access our behaviours, policies and processes. All policies and procedures are held on an online portal ‘Witherslack Way’ and are reviewed and updated at least annually.
Our organisation structure and supply chains
Due to the nature of our business we have a modest supply chain to ensure our needs in terms of our administration, management of our facilities and buildings are properly met. It is our expectation that our suppliers are able to provide details of their own policies supporting their statements and, as a minimum, meet national laws and include human rights principles regarding child labour or bonded or forced labour where documents are withheld, payment of fair wages and payment in money, not kind.
We have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities. Our teams are encouraged to speak up about unethical behaviour, wrongdoing or behaviours they think go against our policies and values. We have an external, third party managed, whistleblowing procedure that supports this communication.
Identification of risk areas
We’ve identified as relatively low risk the organisations in our supply chain with whom we have relationships. Our supply chain encompasses a range of goods, works and services. It is broadly grouped into the following categories:
• Property maintenance.
• Professional services (legal, audit, insurance)
• Recruitment & Marketing services (agencies, training providers)
• Technical services (payroll, DBS checking)
• Purchasing for educational resource for schools which is mainly through national providers.
Witherslack Group is committed to acting ethically and with integrity in all our business dealings. We are working to ensure there is transparency in our own business and throughout our supply chain to seek to ensure that nobody is exploited. We expect suppliers to share this commitment.
Given the nature of our business, it continues to be our view that the risk of modern slavery in our supply chain is low compared to businesses operating in other sectors. However, we are not complacent and will continue to work to improve our policies and procedures to ensure slavery and human trafficking is not taking place anywhere linked with our operations, and that the businesses we choose to partner with understand our stance
Policies in relation to slavery and human trafficking
Witherslack Group’s commitment to acting ethically and ensuring that there is no modern slavery in our supply chains or business is supported by our internal policies.
These recognise our responsibilities and we have control policies in place including:
• Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistleblowers.
• Code of Conduct - our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
• Recruitment, selection and vetting.
• Anti-Bribery and Corruption
• Child Protection Policy and Procedures
Witherslack Group conducts due diligence on all new suppliers. This includes:
• Assessing risks in the provision of particular services
• Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
• They don't use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
• They don't require employees to post a deposit/bond and don't withhold their salaries for any reasons
• They don't require employees to surrender their passports or work permits as a condition of employment
Risk assessment and management
Witherslack Group has raised awareness of modern slavery issues by providing a mandatory e-learning module, written in partnership with the Children’s Society, on modern slavery and trafficking. The learning covers:
• What modern slavery and trafficking are
• The Modern Slavery Act 2015
• Types of trafficking
• Busting myths about trafficking
• Who does trafficking affect and why is trafficking possible?
• Internal trafficking and county lines
• Spotting signs of trafficking
• Reporting concerns about a trafficked child or adult
• Advice and support
What actions have we taken in the last twelve months?
• We have implemented an online portal for all Witherslack Group policies and procedures to ensure documentation is in one place, easily accessible and has robust documentation control.
• We have implemented a confidential third party whistleblowing line that is actively promoted to staff.
• We adapted our approach to wellbeing and support throughout the COVID-19 pandemic, ensuring that employee safety and health was at the heart of our decision making. We continue to offer flexible working to all employees and ensure that employees are supported.
• Our schools have achieved a number of prestigious awards including;
Rights Respecting Schools – supporting our young people to be aware of Rights for children
ECO Schools awards - supporting our children in the development of environmental awareness.
UNICEF Bronze award - has supported the PSHE curriculum and Child’s Rights Charter involvement
What actions will we undertake in the next 12 months
We understand that the modern slavery risk is not static, and we will continue improving our approach to mitigating this risk in the year ahead. Over the next 12 months, we will continue to build on our current approach to managing the risk of slavery and human trafficking within our business as such we will;
• Review and update all Group and Functional policies to ensure reference to and visibility of modern slavery.
• Develop and publish our Social Value Strategy.
• Create and communicate our Supplier Code of Conduct making its acceptance a condition of doing business with Witherslack Group.
• Carry out an internal supplier risk assessment based upon product and labour risk.
• Issue a modern slavery questionnaire to our regular suppliers.
• Incorporate a modern slavery compliance assessment to our regular Quality Assurance Board review process.
• Continue our programme of training for operational colleagues to provide more in-depth knowledge of modern slavery and the warning signs to look out for.
• Implement ‘licence to recruit’ accreditation to hiring managers.
• Continue to monitor and report on any incidents of alleged breaches of modern slavery practices.
This statement outlines our approach to modern slavery and human trafficking and is made pursuant to section 54(1) of the Modern Slavery Act (2015) in the UK and in respect of Witherslack Group. This statement covers 1 April 2020 to 31 March 2021 and has been approved by the board of Witherslack Group at the board meeting on 25th March 2021.
Signed and approved by: