Modern Slavery Statement

Last review date: 1st September 2026

Next review date: 1st September 2027

Introduction

This Modern Slavery Statement is published voluntarily by Raise the Bar Ltd in support of the principles of section 54 of the Modern Slavery Act 2015 and reflects our commitment to preventing modern slavery and human trafficking within our operations and supply chains.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which involve the exploitation of individuals for personal or commercial gain.

We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We recognise our responsibility to identify and manage potential risks of modern slavery within our own operations and supply chains.

Our Business

Raise the Bar Ltd designs and delivers a broad range of bespoke development programmes to public and private sector clients throughout the UK.

In addition, we work with UK employers to deliver apprenticeships to their employees, primarily remotely, leading to recognised qualifications that build capability in areas such as continuous improvement, business administration, project delivery, AI and automation, and professional coaching.

Raise the Bar Speakers is our speaker bureau, providing clients with speakers to inspire their teams through digital and in-person events and conferences globally.

To find out more about our business, please visit www.raisethebar.co.uk.

Our Supply Chain

In delivering our services, we work with a range of suppliers and external partners, including professional service firms, utility suppliers, IT vendors, consultants, industry partners, representative bodies and technology platform providers.

We also engage a small pool of self-employed external consultants who provide additional knowledge and expertise to our learners. Many of these are respected, experienced professionals who have partnered with the business for several years.

We expect managers responsible for supplier relationships to remain alert to potential ethical or compliance concerns and escalate these appropriately, with overall accountability resting with the Executive Board.

We maintain close working relationships with our clients, primarily through our Client Solutions team, to support transparency, trust and effective communication.

As an apprenticeship training provider, we also recognise our safeguarding responsibilities towards learners. All apprenticeship learners receive an onboarding process which includes information about expectations, safeguarding and the channels available to raise concerns. Our Coaches receive safeguarding training to support their ability to recognise and respond appropriately to concerns arising through their ongoing relationships with learners.

Our Policies & Controls

We have a suite of policies and procedures which support ethical business practices and help us identify, prevent and respond to potential concerns relating to modern slavery and exploitation, including:

ESG & Corporate Social Responsibility Policy
Business Ethics Policy
Equality, Diversity & Inclusion Policy
Prevent & Safeguarding Policy
Procurement Policy
Safer Recruitment Policy
Whistleblowing Policy

We are committed to working with suppliers who demonstrate appropriate ethical and professional standards and expect those acting on our behalf to conduct their activities responsibly and in accordance with applicable legislation.

Our safeguarding and whistleblowing arrangements provide routes for employees to raise concerns about unethical practices, exploitation or suspected wrongdoing, including concerns involving learners or third parties.

These policies are regularly reviewed and developed to reflect changes in legislation, guidance and business practices, with oversight from the Executive Board.

Risk Management & Due Diligence

We recognise that, although the nature of our services and the geographical location of our operations present a relatively low risk of modern slavery, risks can exist within any organisation or supply chain.

We therefore take a proportionate, risk-based approach to identifying and managing potential risks within our operations and third-party relationships.

Our existing controls include:

We do not routinely utilise temporary agency workers or flexible short-term labour models within our employed workforce.
Where external consultants or speakers are engaged, we apply appropriate supplier due diligence processes.
We operate fair and transparent recruitment and onboarding processes, including verifying the identity and right to work of prospective employees, using an approved Identity Service Provider (IDSP) where applicable, and issuing clear written terms and conditions of employment.
We take appropriate steps to establish the right-to-work status of individuals engaged directly by the business, including self-employed consultants and speakers where applicable, and seek relevant assurances from third-party suppliers and agencies regarding their compliance with employment and right-to-work requirements.
We ensure employees are paid in accordance with applicable National Minimum Wage and National Living Wage requirements.
All learner-facing or learner-accessible roles are subject to an Enhanced DBS check prior to starting employment, with checks renewed every three years as a condition of employment.
We undertake appropriate identity and employment verification checks, including reviewing relevant personal and payroll information, to help ensure that individuals engaged by the business are correctly identified and that employment and payment arrangements are legitimate.
As a remote-first organisation, we recognise the importance of maintaining regular contact and appropriate oversight of our team members. We promote a camera-on culture during virtual meetings and ensure that all roles involve daily interaction with colleagues. This supports employee wellbeing, helps maintain confidence in the identity of individuals undertaking work and provides opportunities to identify and respond to potential concerns relating to identity substitution, unauthorised working or exploitation.
We seek to work with reputable suppliers who demonstrate appropriate ethical and professional standards.
We maintain awareness of relevant legislative and professional developments through professional memberships, continuing professional development and engagement with industry guidance.

As part of our efforts to minimise the risk of modern slavery and human trafficking within our supply chain, we seek to establish relationships with reputable suppliers who demonstrate appropriate professional and ethical standards.

We recognise that risks may vary depending on the nature of the services provided and our relationship with individual suppliers. Where potential concerns are identified, we will seek further information or assurances as appropriate and take action where necessary to ensure our expectations regarding ethical business practices are maintained.

Remedial Action

If we identify or suspect modern slavery within our operations or supply chain, we are committed to responding promptly, responsibly and with appropriate consideration for the safety and wellbeing of any individuals affected.

Depending on the circumstances, our response may include:

Immediate safeguarding and escalation – Taking appropriate action to protect individuals who may be at risk and escalating concerns through our safeguarding or relevant internal reporting procedures.
Investigation and assessment – Reviewing available information to understand the nature and extent of the concern, involving appropriate external authorities or specialist organisations where necessary.
Engagement with relevant parties – Where appropriate and safe, engaging with suppliers or business partners to establish the circumstances and identify suitable corrective actions.
Remediation and corrective action – Working with relevant parties to address identified issues, improve working practices and reduce the risk of recurrence, prioritising the interests of affected individuals.
Suspension or termination of business relationships – Considering suspension or termination where the concerns are serious, cannot be adequately addressed or where continued engagement would be inappropriate, taking account of any potential impact on affected individuals.
Reporting and specialist support – Referring concerns to law enforcement, safeguarding authorities or specialist support organisations where appropriate, including seeking guidance on support available to potential victims.
Review and continuous improvement – Reviewing any incidents or identified risks to determine whether changes are required to our policies, training, supplier arrangements or internal controls.

Where a significant incident also presents a wider operational risk, we will follow our Business Continuity Plan as appropriate.

Training & Awareness

We are committed to raising awareness and investing in the knowledge and understanding of our employees so they can recognise the risks and potential indicators of modern slavery and human trafficking within our business, supply chains and wider society.

All learner-facing employees complete mandatory Prevent & Safeguarding training provided by the Education & Training Foundation (ETF). This includes awareness of modern slavery and is refreshed annually, with relevant updates, to support employees in recognising and responding appropriately to concerns or disclosures that may arise through their relationships with learners.

All employees complete annual Modern Slavery e-learning through our learning management system, supporting awareness of the risks, warning signs and appropriate reporting routes.

Employees and managers involved in recruitment processes are also required to complete Safer Recruitment training provided by the ETF.

We review our training requirements to ensure that employees continue to receive appropriate guidance and awareness relevant to their responsibilities.

Monitoring & Review

We recognise the importance of reviewing the effectiveness of our approach to preventing modern slavery and identifying opportunities for continuous improvement.

We monitor our arrangements through existing people management, safeguarding, recruitment and supplier due diligence processes.

Areas considered as part of our ongoing review include:

Completion of relevant mandatory employee training
Compliance with recruitment and right-to-work checking procedures
Supplier due diligence and identification of potential risks
Safeguarding, whistleblowing or other concerns relating to exploitation, and the actions taken in response
Changes in legislation, guidance or business activities which may require additional controls

Findings from these activities inform any improvements required to our policies, processes and training arrangements.

This statement is reviewed annually in September to ensure it remains accurate and reflects our current practices, policies and procedures. It may also be updated sooner where significant changes to our operations, supply chains or relevant legislation require it.

Approval

This Modern Slavery Statement has been approved by the Executive Board of Raise the Bar Ltd.