Modern Slavery

Crosby Training > Policies & Procedures > Modern Slavery

POLICIES & PROCEDURES:
MODERN SLAVERY & HUMAN TRAFFICKING

Crosby Training is committed to preventing slavery and human trafficking in its operations and those of partner organisations. We comply with the Modern Slavery Act 2015 and ensure no slavery or trafficking occurs. This statement is reviewed annually and applies continuously, not limited to a contract year.

ORGANISATIONAL STRUCTURE

Crosby Training operates primarily in the Liverpool City Region and partners with organisations to provide work placements, specialist training, and employability support. There are no overseas operations or partners.

LEGAL & FUNDING CONTEXT

We comply with the Modern Slavery Act 2015 and funder expectations, including DWP, ASF, Riverside College, and Jobcentre Plus. Partners are informed of their legal obligations and required to comply with ethical standards.

RISK ASSESSMENT & MANAGEMENT

Risks arise in high-risk sectors (e.g., hospitality, construction), specialist training, and work with vulnerable learners. Key risk areas:

  • Learners entering employment in high-risk sectors.
  • Partners operating in sectors with known exploitation risks.
  • Informal or unregulated work-based learning arrangements.

Mitigation measures:

  • Careful partner selection.
  • Compliance with legislation and ethical standards.
  • Learner guidance on rights and exploitation.
  • Safeguarding procedures including modern slavery references.
  • Monitoring complaints and incidents.  
  • No incidents have been reported to date.

POLICIES & PROCEDURES

  • Whistleblowing Policy: Enables reporting of slavery or trafficking concerns safely.
  • Safeguarding Policy: Treats slavery and trafficking as safeguarding concerns, supported by staff induction and annual training.
  • Recruitment & Selection: Staff recruited directly or via verified agencies; learners predominantly UK-based.

TRAINING & AWARENESS

  • Staff briefings on modern slavery included in safeguarding training.
  • Key staff receive annual refresher training.
  • Learners are informed of rights, sector risks, and reporting mechanisms.

PARTNER ORGANISATION ASSURANCE

  • Partners must comply with the Modern Slavery Act and Crosby Training policies.
  • Non-compliant partners are removed from approved lists and may only return upon demonstrating compliance.

PERFORMANCE INDICATORS

Crosby Training monitors modern slavery risk management through quality and safeguarding processes, annual reports, and Quality Improvement Plans.

This is a Summary: you can read our full Modern Slavery & Human Trafficking Policy here.