Modern Slavery Statement

Last review date: 31st August 2025

Next review date: 31st August 2026

Introduction
This modern slavery statement is made on behalf of Raise the Bar Ltd pursuant to section 54(1) Modern Slavery Act 2015 and applicable to our financial year 2025/2026.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We have a zero-tolerance approach and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing procedures to ensure modern slavery is not taking place anywhere in our own business or in any of our 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, Raise the Bar Ltd works with employers in the UK to deliver apprenticeships to their staff, remotely, leading to recognised qualifications in leadership, management, and coaching. Furthermore, Raise the Bar Speakers is a speaker bureau working on digital events and conferences globally.

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

Our Supply Chain
We work directly with our clients who we deliver learning experiences to their employees. Due to the service and products we provide, our contacts are usually senior employees within the L&D or HR profession. Our Client Solutions team partner closely with our clients and we pride ourselves on our personable and dedicated account management to build trust and transparency within our client relationships.

We engage with a small pool of self-employed external consultants who offer us additional knowledge and expertise for our learners. The consultants are respected, experienced professionals within their field who have partnered with the business for many years.

All apprenticeship learners are provided with a thorough onboarding process where they are provided with information on standards and expectations along with channels to raise and report any concerns relating to ethical business practices. All our Coaches are trained In Safeguarding & Prevent and are passionate about the safety and wellbeing of each learner alongside the educational and personal development goals.

In order to provide services to clients, we work with a range of suppliers including but not limited to: professional service firms, utility suppliers, IT vendors, consultants, industry business partners, representative bodies and technology platform providers. We have a Head of Business Support who works closely with our suppliers and Executive team, enforcing ethical standards of service and identifying any concerns with regards to compliance.

Our Policies & Controls
To embed and govern the above, we have a suite of policies and procedures which ensure we conduct an ethical business operation, including:
• Corporate Social Responsibility Policy
• Business Ethics Policy
• Equality, Diversity & Inclusion Policy
• Prevent & Safeguarding Policy
• Procurement Policy
• Safer Recruitment Policy
• Whistleblowing Policy

We ensure that our suppliers are aware of our high standards for business ethics and integrity and we share the relevant policies with them to ensure value alignment and that our expectations are managed from the outset of any partnership.

These policies are continually reviewed and developed upon by the People team and the Executive Board.

Risk Management & Due Diligence
We do not consider that we operate in high-risk sectors or locations because of the nature of the services we provide and the location and composition of our supply chain and suppliers.

In addition:
• We do not utilise any flexible short-term labour models, such as agency workers, in any part of our business.
• We conduct thorough employment checks ensuring that prospective employees have the right to work in the UK, using an approved IDSP provider to complete robust identification checks.
• All learner facing/learner accessible roles must have an Enhanced DBS check prior to starting employment and renew this every 3 years as a condition of their employment.
• We cross check key employee data such as identification documents, dates of birth, home address, phone number and bank details to ensure they match the employee/learner presenting to us.
• We ensure that suppliers are reputable and adhere to our ways of working and standards.
• We stay up to date with developments via professional memberships and continuing professional development across all senior management roles within the business.

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chain, our suppliers must declare the following through a questionnaire:
• Recruitment procedures and labour models used
• Commitment to paying the national minimum wage
• Compliance to reasonable working hours and working conditions
• Conducting risk assessments
• Having procedures in place for dealing with any concerns or incidents of modern slavery or human trafficking (including protecting whistle – blowers)
• Assigning responsibility for this area to senior colleagues in the business

Remedial Action
If we identify evidence of modern slavery within our operations or supply chain, we will take the following actions:
1. Immediate Investigation – Conduct a thorough investigation to assess the nature and extent of the issue.
2. Engagement with the Supplier or Party Involved – Work with the relevant supplier or business partner to understand the situation and determine appropriate remedial actions.
3. Remediation & Corrective Action Plans – Require the responsible party to take corrective measures, such as improving working conditions, releasing affected individuals, or enhancing compliance programs.
4. Suspension or Termination of Business Relationships – If the issue is severe or the supplier fails to take corrective action, we may suspend or terminate contracts.
5. Reporting to Authorities – Where appropriate, report the case to law enforcement or relevant regulatory bodies.
6. Support for Victims – Work with NGOs or relevant organisations to provide support and remediation for affected individuals.
7. Review & Strengthen Policies – Use findings from the incident to strengthen our policies, training, and risk assessment processes to prevent recurrence.

Should there be a major concern or crisis situation, we will follow the company’s Business Continuity Plan.

Training & Awareness
We are raising awareness and continually taking time to invest in educating our team members in order to recognise the risks of modern slavery and human trafficking in our business, wider society and supply chains.

All learner facing team members complete mandatory Prevent & Safeguarding Training provided by the Education & Training Foundation (ETF). This training covers Modern Slavery and is repeated annually (with necessary updates) to ensure we remain vigilant due to the possibilities for any disclosures or suspicions arising due to the long term close working relationship that is developed between a coach and learner.

All other team members complete annual e-learning in Modern Slavery provided via our e-learning provider which is an approved UK compliance course.

All team members and managers involved in recruitment procedures must complete Safer Recruitment training which is provided by the ETF.

Approval
This modern slavery and human trafficking statement was approved by the Executive Board of Raise the Bar Ltd.

Monitoring & Review
This statement will be monitored annually to review its effectiveness and will be updated in accordance with necessary changes.

Approval
This statement was approved by the Executive Board of Raise the Bar.