Modern slavery statement

At Trinity we recognise that slavery and human trafficking are an increasing concern on a global basis and we are committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chains. We also expect the same high standards from our contractors, suppliers and other business partners and will not work with any organisation where we suspect any involvement in modern slavery.

Structure of the organisation

Trinity College London is an international exam board providing qualifications in English language and the performing arts in approximately 70 countries worldwide. It is a registered charity in England and Wales (no. 104792) and in Scotland (no. SC 049143). In the financial year 2021-22, the average number of employees calculated on a full-time equivalent basis was 292 and the annual turnover was £33,884m.

To deliver our exams and assessments, we work with a network of service providers, including national and area representatives, as well as registered exam centres and hubs (schools, private colleges, universities and other educational bodies). Other key service providers include our recruitment agencies, printers and distributors, data processors, travel agents, research partners, consultants and professional advisers. We also enter into commercial agreements and collaboration projects with strategic partners.

Policies

We are committed to making all our staff and contractors aware of our view on slavery and human trafficking to mitigate the risk of modern slavery. We have in force the following policies and procedures:

  • Modern Slavery Policy
  • Whistleblowing Policy
  • Policy and Procedure on Reporting Malpractice
  • Recruitment Procedure
  • Safeguarding and Child Protection Policy & Procedures

Our policies and procedures are designed to:

  • establish and assess areas of potential risk in our business and supply chains
  • monitor potential risk areas
  • reduce the risk of occurrence
  • provide adequate protection for whistleblowers

We seek to ensure that our suppliers are aware of our policies and procedures (they are publicly available on our website) and adhere to the same high standards as our own staff.

Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have approached a representative sample of our suppliers for the financial year to 31 March 2022 seeking confirmation of their compliance with the Modern Slavery Act 2015.

We have also put in place a new contract management system in 2021/22 to ensure that Trinity has a comprehensive supplier and contract data base for existing suppliers.

Risk and compliance

We do not consider that we operate in a high-risk sector. Nevertheless, we review our supply chain and preferred supplier list as part of our regular inspection cycle and will terminate contracts or take remedial action if instances of modern slavery come to light.

We have not had any reports of any behaviours or practices that come within the scope of the International Labour Organization (ILO) indicators of forced labour.

Effectiveness

We use key performance indicators (KPIs) to measure how successful we have been in ensuring that slavery and human trafficking are not taking place in any part of our business or supply chains.  These KPI’s are as follows:

The number of questions or reports we have received from employees, the public or law enforcement agencies to indicate that modern slavery practices had been identified in our supply chain or through the retention of contractors. There have been no questions or reports for the financial year to 31 March 2022.

The number of contractual relationships terminated as a result of breaches of our policies (above). There have been no contractual relationships terminated for the financial year to 31 March 2022.

Continuing actions

Employees and contractors (‘staff’) are required to adhere to the Trinity Code of Conduct and are encouraged to identify and report any potential breaches of our Modern Slavery Policy.

We provide periodic training on Modern Slavery for our staff and continue the reach of our targeted training for our subsidiaries network of representatives overseas.

Modern slavery compliance is encompassed within the risks in our risk register which is reviewed regularly by the Executive.

Trinity will submit this statement to the Government’s modern slavery statement registry.

Approval of this statement

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Trinity College London's slavery and human trafficking statement for the financial year commencing 1 April 2021 and ending 31 March 2022. It was approved by the Board of Directors on 4 May 2022.

 

Mr. Mark Damazer CBE
Chairman of the Board of Trustees
Trinity College London

Date:  4 May 2022

 

 

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