Introduction:
This Modern Slavery Statement is issued by United Kingdom Road Offender Education (UKROEd) in accordance with the Modern Slavery Act 2015. UKROEd is committed to preventing modern slavery and human trafficking from affecting its operations and supply chains. This statement sets out the steps that we have taken in respect of the financial year ending 31 March 2024 to mitigate the risk to ensure Modern Slavery is not allowed the opportunity to flourish in our supply chain or business.
Structure and Supply Chains:
UKROEd is a not-for-profit company limited by guarantee, responsible for the management and administration of the National Driver Offender Retraining Scheme (NDORS) in the United Kingdom. Our supply chains primarily consist of goods & service providers, training course providers, and technology partners.
Policies in Relation to Slavery and Human Trafficking:
UKROEd is dedicated to preventing modern slavery and human trafficking from occurring in any aspect of our operations or supply networks. Our core principles revolve around valuing others and conducting ourselves with honesty and integrity, and we expect all our team members to uphold these standards. To support this commitment, we have developed and maintain the following policies and procedures:
- Modern Slavery Policy: Our Modern Slavery Policy outlines our zero-tolerance approach to modern slavery and human trafficking and provides guidance to employees and stakeholders on reporting concerns.
- Code of Professional Conduct: Our Code of Conduct sets out the ethical standards we expect from our employees, suppliers, and partners, including respect for human rights and labour standards. In addition, all staff are expected to follow the UKROEd Values and Behaviours framework.
- Whistleblowing Procedure: We have a confidential whistleblowing procedure that encourages employees and others to report any concerns related to modern slavery without fear of retaliation.
- Recruitment: We adopt a stringent approach to hiring, which includes verifying the eligibility of all employees to work in the UK to prevent human trafficking and involuntary labour. We exclusively collaborate with reputable recruitment agencies, all of which are required to affirm their commitment to complying with UK laws against modern slavery.
- Health and Safety: Our foremost objective is to create a secure working environment within our premises. We prioritise the physical and mental wellbeing of our staff and actively support it through various employee wellbeing programs.
- Procurement: Our policies place personal responsibility on our team members to ensure that expenditure is only incurred with suppliers who uphold ethical business practices, maintain a strong reputation and comply with the Modern Slavery Act when mandated to do so.
- Anti-Bribery: At UKROEd, we maintain a strict zero-tolerance stance on bribery, and all our personnel undergo training to identify and prevent bribery. Furthermore, we are committed to taking resolute action against any individuals involved in bribery, which serves to prevent unethical procurement practices and the use of unscrupulous suppliers.
Due Diligence Processes in Relation to Slavery and Human Trafficking:
UKROEd conducts business predominantly in the UK, a lower risk jurisdiction where slavery and human trafficking is prohibited and criminalised by law.
UKROEd conducts due diligence processes to identify and mitigate the risks of modern slavery and human trafficking within its supply chains. Our due diligence measures include:
Supplier Assessments: We assess our suppliers’ commitment to ethical labour practices and compliance with modern slavery laws as part of our procurement process. We also proactively review the published slavery and human trafficking statements of our suppliers and vendors.
KPI’s : UKROEd will continue to develop a meaningful set of KPI’s to ensure we are able to effectively monitor our continued commitment to preventing Modern Slavery.
Risk Assessment and Management:
UKROEd regularly assesses the risks of modern slavery and human trafficking within both its own operations and supply chains. We take a risk-based approach to identify and prioritise potential areas of concern.
Our risk assessment includes:
Geographical Risk: We consider the regions and countries in which our suppliers operate and assess the prevalence of modern slavery in those areas.
Sectoral Risk: We evaluate the specific sectors and industries in which our suppliers are engaged to identify any potential risks.
In the provision of our own services, we rely upon a stable and well-trained workforce, many of whom hold professional qualifications and maintain affiliations with professional associations. All of our employees are subject to formal employment contracts, which grant them the option of termination. They are all paid at least the national living wage as well as receiving other fixed and flexible benefits. We are satisfied that the risk of slavery or human trafficking occurring in our own business is low.
Effective Action Taken to Address Modern Slavery:
UKROEd is committed to taking effective action to address modern slavery and human trafficking. We have implemented various initiatives, including:
Course Provider Engagement: We work closely with our course providers to raise awareness of modern slavery risks and provide support for improvement where necessary. This activity forms a central pillar of licensing NDORS course providers and the Annual Provider Review.
Monitoring and Auditing: We conduct regular audits and monitoring of our supply chains to ensure compliance with our policies and contractual obligations. UKROEd have also implemented a specific Modern Slavery Action Plan to ensure effective monitoring and oversight by senior executives is achieved.
Training on Modern Slavery and Trafficking:
We offer training to all our staff, with a specific focus on those engaged in procurement and supply chain management, to increase their understanding of modern slavery and human trafficking issues. We have made it mandatory for trainers holding NDORS licenses (administered by UKROEd) to attend Modern Slavery training. This resulted in 327 individuals receiving modern slavery training from UKROEd during the 23/24 fiscal year. This training covers:
- Recognition of signs of modern slavery and human trafficking.
- Reporting mechanisms and procedures.
- Compliance with relevant policies and legal obligations.
All new UKROEd staff are required to attend Modern Slavery training as part of their induction programme and are signposted to available resources such as the Modern Slavery Aide Memoir which is available to all UKROEd website members which includes, staff, course trainers, course providers, Police staff and UKROEd board members.
Conclusion:
UKROEd is committed to taking all necessary steps to prevent modern slavery and human trafficking in our operations and supply chains. This Modern Slavery Statement reflects our ongoing commitment to transparency and the continuous improvement of our practices in this regard.
This statement has been approved by the Chief Executive Officer and will be reviewed annually to ensure its continued effectiveness.
Signed
Ruth Purdie Chief Executive Officer, UKROEd Limited
