Anti-slavery & human trafficking policy

Introduction

Modern slavery is a serious crime and a violation of fundamental human rights. It encompasses various forms of exploitation, including slavery, servitude, forced and compulsory labour, bonded labour, child labour, and human trafficking. The United Kingdom’s Modern Slavery Act 2015 was introduced to combat these practices and improve transparency in supply chains. This legislation requires organisations to take proactive steps to identify, prevent, and address risks of modern slavery in their operations and supply chains.

As a socially responsible organisation, we are committed to upholding the principles of this Act. Preventing modern slavery is not only a legal obligation but also a moral imperative to ensure that our business operations contribute to a fair, ethical, and sustainable global economy. This policy outlines our commitments, measures, and actions to safeguard against modern slavery and trafficking across all aspects of our organisation and supply chains.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels and contractors. Malvern International strictly prohibits the use of modern slavery and human trafficking in our operations. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation.

Organisation Structure

Malvern International is a global education company operating across multiple locations, providing high-quality learning experiences to students worldwide. Our organisational structure encompasses a diverse team of professionals working across various divisions, including academic delivery, student support, operations, and corporate services. Additionally, we collaborate with a network of trusted suppliers, contractors, and partners who contribute to our mission of delivering outstanding education. This interconnected structure necessitates a robust approach to ensuring transparency, accountability, and compliance with our anti-slavery and human trafficking commitments.

Commitments

Commitments

We are a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• To have a zero-tolerance approach to modern slavery in our organisation.
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.
• Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations.
• We take a risk-based approach to our contracting processes and keep them under review.
• We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.

We may require:

• Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with this Policy.
• Suppliers engaging workers through a third party to obtain that third parties’ agreement to this Policy.
• We will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with this Policy.
• If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking within our supply chains and business, we are committed to ensuring that everyone who requires it will receive appropriate training on this critical issue in 2025. This training will aim to raise awareness, equip staff with the knowledge to identify potential risks, and address any areas of concern.

Performance Indicators

As part of our ongoing commitment to combating modern slavery, Malvern International is setting two key objectives for 2025:

1. By 31st August 2025, all staff working in Purchasing, Operations, Human Resources, and the Executive Team will have completed comprehensive training on Modern Slavery. This training will focus on raising awareness, equipping staff with the tools to identify potential risks, and providing guidance on addressing any areas of concern.
2. Over the next 12 months, we will undertake a thorough review of our procurement practices and supply chain processes. Our goal is to implement a formalised supplier approval process and strengthen purchasing controls, ensuring a more transparent and accountable approach to working with suppliers and mitigating the risk of modern slavery in our operations.

Policy approval