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, Malvern International is committed to upholding the principles of this Act. Preventing modern slavery is not only a legal obligation but 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 human trafficking across all aspects of our organisation and supply chains.
As an education provider inspected by the Independent Schools Inspectorate (ISI), Malvern House additionally recognises its duty of care to students, including the obligation to be alert to indicators that a student may be a victim of modern slavery, exploitation, or human trafficking. This duty sits within our broader safeguarding framework and is taken with the utmost seriousness.
Scope
This policy applies to:
- All persons working for us or on our behalf in any capacity, including employees at all levels, contractors, agency workers, volunteers, and consultants.
- All students enrolled at Malvern House, in so far as this policy relates to the identification of and response to potential victims of modern slavery or exploitation.
- All suppliers, recruitment agencies, accommodation providers, and other third parties engaged by Malvern International.
Malvern International strictly prohibits the use of modern slavery and human trafficking in our operations and supply chains. We are committed to implementing systems and controls to ensure that modern slavery is not taking place anywhere within our organisation or among those working on our behalf.
Organisation Structure and Risk Context
Malvern International is an education company operating across multiple locations in the UK, providing high-quality learning experiences to students worldwide. Our activities involve a range of operational areas that carry varying degrees of risk in relation to modern slavery and human trafficking. The areas we have identified as carrying the most relevant risk include:
- Student recruitment and admissions — Malvern House recruits students internationally, often through overseas agents. We recognise the risk that students may in some cases be controlled, coerced, or exploited by third parties involved in their recruitment or travel arrangements.
- Accommodation and homestay provision — where students are placed in accommodation arranged by or through the School, there is a duty to ensure providers meet appropriate standards and that students are not subject to exploitation in those settings.
- Cleaning, catering, and facilities contractors — workers in these sectors can be vulnerable to labour exploitation. We assess contractors in these categories as part of our supplier approval process.
- Recruitment and staffing agencies — where staff are engaged through third party agencies, we require confirmation of compliance with this policy and applicable legislation.
Students as Potential Victims
Malvern House’s international student population means staff must be alert to the possibility that a student may be a victim of modern slavery, trafficking, or exploitation. This is particularly relevant where a student:
- Appears to be controlled by another person and is unable to speak or act independently
- Has had travel documents, passport, or identity documents withheld by a third party
- Shows signs of physical abuse, malnutrition, or extreme fatigue
- Appears fearful, anxious, or reluctant to engage with staff without a third party present
- Is unable to confirm their own address or living arrangements
- Appears to be working under duress or in conditions inconsistent with their student status
- Has limited access to their own money or finances
Any member of staff who identifies or suspects that a student may be a victim of modern slavery or trafficking must report their concerns immediately to the Designated Safeguarding Lead (DSL). This policy should be read in conjunction with the School’s Safeguarding Policy, which sets out the full procedure for responding to safeguarding concerns. Where there are reasonable grounds to believe a student is a victim of modern slavery or trafficking, a referral will be made to the National Referral Mechanism (NRM) and, where appropriate, to statutory agencies.
Commitments
Malvern International expects everyone working with us or on our behalf to support and uphold the following:
- A zero-tolerance approach to modern slavery and human trafficking in our organisation and supply chains.
- The prevention, detection, and reporting of modern slavery 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 regular review.
- We assess whether circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties.
We will 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 party’s agreement to this policy.
We will, where appropriate:
- Carry out audits of suppliers for their compliance with this policy.
- Take appropriate action where individuals or organisations working on our behalf are found to have breached this policy. This may range from requiring remediation to terminating the relationship, depending on the nature and severity of the breach and the best outcome for those affected.
Reporting Concerns
Any member of staff, student, or third party who suspects that modern slavery or human trafficking is taking place whether in relation to a student, a member of staff, or within our supply chain should report their concern immediately.
Internal reporting:
Concerns should be reported to the Head of HR or the Designated Safeguarding Lead (DSL) in the first instance. Where the concern relates to a student, the DSL must always be informed.
External reporting:
- Modern Slavery Helpline: 0800 0121 700 (free, 24 hours a day, 7 days a week)
- National Referral Mechanism (NRM): for referring potential victims of modern slavery to the Home Office — guidance is available at www.gov.uk/government/publications/human-trafficking-victims-referral-and-assessment-forms
- Police: where there is an immediate risk to a person’s safety, staff should call 999.
All reports will be treated seriously and in confidence. No member of staff or student will suffer any detriment as a result of raising a concern in good faith under this policy.
Training
Malvern International is committed to ensuring that all relevant staff understand the risks of modern slavery and human trafficking and are equipped to identify and respond to concerns.
Training will be provided to:
- All new staff as part of their induction programme.
- All staff in Purchasing, Operations, Human Resources, and the Executive Team on an annual basis.
- All teaching and student-facing staff, with specific focus on identifying indicators of exploitation among students.
Training will be reviewed annually to ensure it remains current and reflects any changes in legislation or guidance. Records of training completion will be maintained by HR.
Supply Chain Risk Assessment and Procurement
Malvern International conducts ongoing review of its procurement practices and supplier relationships to identify and mitigate the risk of modern slavery. Our approach includes:
- A formalised supplier approval process requiring confirmation of compliance with the Modern Slavery Act 2015 for all new suppliers.
- Inclusion of anti-slavery and human trafficking clauses in contracts with suppliers in higher-risk categories, including recruitment agencies, accommodation providers, and cleaning and facilities contractors.
- Periodic review of existing supplier relationships to assess ongoing compliance.
- Escalation of concerns to the COO and CEO where non-compliance is identified.
Performance Indicators
The following indicators will be used to monitor the effectiveness of this policy:
- All staff in Purchasing, Operations, Human Resources, and the Executive Team will complete modern slavery awareness training by 31 December 2026, with completion records held by HR.
- All new staff will receive modern slavery awareness as part of their induction from September 2026 onwards.
- A full review of supplier contracts in higher-risk categories will be completed by 31 December 2026, with anti-slavery clauses confirmed or added as appropriate.
- The formalised supplier approval process will be operational for all new suppliers from September 2026.
- This policy will be reviewed annually, with a report to the CEO on compliance, training completion, and any concerns raised or investigated during the preceding year.
Safeguarding Cross-Reference
This policy operates alongside and must be read in conjunction with the Malvern House Safeguarding Policy. Where any concern under this policy also gives rise to a safeguarding concern — particularly in relation to a student — the Safeguarding Policy takes precedence, and the Designated Safeguarding Lead must be informed immediately.