• 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 to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.
• This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time.

1. Scope

• 2.1 The following roles may be affected by this policy: All staff Registered Manager Osagie Benson Other management 2.2 The following Service Users may be affected by this policy: Service Users 2.3 The following stakeholders may be affected by this policy: Commissioners Local Authority.

2. Objectives :

• To promote awareness of concerns surrounding slavery and human trafficking and promote the commitment of GLOBAL NORTH LONDON BUSINESS SCHOOL in addressing slavery and human trafficking in all its forms. An annual statement will be produced, where applicable. 3.2 To ensure that identification, protection, care and support for victims of modern slavery and human trafficking is at the heart of our safeguarding procedures at GLOBAL NORTH LONDON BUSINESS SCHOOL.

3. Policy :

• 4.1 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 include the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
• 4.2 GLOBAL NORTH LONDON BUSINESS SCHOOL has a zero-tolerance approach to modern slavery within the business and supply chains and we are committed to acting ethically and with integrity in all our dealings and relationships. We will implement and enforce effective systems and controls to ensure that modern slavery is not taking place anywhere in GLOBAL NORTH LONDON BUSINESS SCHOOL or within any third parties (agencies) that we are associated with.
• 4.3 All staff will be made aware of the issues surrounding slavery and human trafficking, whilst being encouraged and supported to report any concerns to GLOBAL NORTH LONDON BUSINESS SCHOOL management. GLOBAL NORTH LONDON BUSINESS SCHOOL will also support any staff that may be subject to slavery or human trafficking.

RESPONSIBILITY FOR THE POLICY :

• Our organisation has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it The Group Purchasing Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.

COMPLIANCE WITH THE POLICY :

• You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager OR the Procurement Department as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
• You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.
• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your manager or the Procurement Department. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.
• Reporting Modern Slavery and Human Trafficking Concerns The following procedure must take place where there are any concerns that someone is a victim of modern slavery or human trafficking.
• GLOBAL NORTH LONDON BUSINESS SCHOOL must ensure that staff are aware that victims of modern slavery or trafficking will often not self-identify. Many will present with a different issue. 1)
• A concern is identified -This could be a Service User as a victim or perpetrator, or a Service User informs us of a concern they have 2
• If an individual is, or group of people are, in immediate risk of danger or harm, the police must be immediately notified on 999 3
• The staff member must discuss this with their line manager (where appropriate) and the City ofg London immediately 4
• The City ofg London contacts and escalates the concern immediately to City of London Safeguarding Adults Team 5
• A notification is made to the CQC via the provider portal
• 5.2 Safer Recruitment All staff engaged with providing services at GLOBAL NORTH LONDON BUSINESS SCHOOL will be subject to thorough and rigorous recruitment procedures that will include a DBS check, identity check, confirmation of validity to work in the UK, employment history, suitability for the role and references.
• This will minimise the chance of employing a person that has been, or is subject to, slavery or human trafficking.
• GLOBAL NORTH LONDON BUSINESS SCHOOL will follow PR16 - Right to Work Checks Policy and Procedure to ensure that a robust and fair process is followed at all times.
• 5.3 GLOBAL NORTH LONDON BUSINESS SCHOOL will only use staff provided by third-party organisations (such as agencies) that are either registered with the regulator or who can confirm that the staff being supplied are free to work in the UK and meet all the requirements for the role being provided for.

COMMUNICATION AND AWARENESS OF POLICY :

• Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
• Training, All staff will undertake training on Modern Slavery and Human Trafficking. This will ensure that they are aware of the indicators of modern slavery which include: Individuals not being paid for the work they undertake Individuals being held in debt-bondage (being told they “still” owe money after having paid off a previous debt) An individual’s passport being held by their “employer” in order to keep the individual at work Multiple benefit claimants having their benefits being paid into the same account An individual not having the freedom of movement (i.e. passport being taken) Clear exploitation of an individual by another for financial or sexual gain Shows signs of physical or psychological abuse, look malnourished or unkempt, anxious/agitated or appear withdrawn and neglected. They may have untreated injuries Rarely be allowed to travel on their own, seem under the control, the influence of others, rarely interact or appear unfamiliar with their neighbourhood or where they work Relationships which do not seem right - for example, a young teenager appearing to be the boyfriend/girlfriend of a much older adult Be living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address Have no identification documents, have few personal possessions and always wear the same clothes day in and day out. What clothes they do wear may not be suitable for their work Have little opportunity to move freely and may have had their travel documents retained, e.g. passports Be dropped off/collected for work on a regular basis either very early or late at night Unusual travel arrangements - children being dropped off/picked up in private cars/taxis at unusual times and in places where it is not clear why they would be there Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their family.

BREACHES OF THIS POLICY :

• Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Review of Effectiveness

• GLOBAL NORTH LONDON BUSINESS SCHOOL intends to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in the supply chains of our providers.
• We will also continue to: Support our staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working in Care can have in keeping present and potential future victims of modern slavery and human trafficking safe Gain assurance that all staff at GLOBAL NORTH LONDON BUSINESS SCHOOL have access to training on how to identify victims of modern slavery and human trafficking Review the Safeguarding Policy and Procedure at GLOBAL NORTH LONDON BUSINESS SCHOOL to ensure that Modern Slavery and Human Trafficking are integral within the content and staff are directed to support and advice as needed
• 5.11 Indicators of Forced Labour Individuals may show signs of psychological or physical abuse. They might appear frightened, withdrawn or confused Workers may not have free movement and may always be accompanied Individuals often lack protective equipment or suitable clothing and have not been trained to safely fulfil the requirements of the role The person may not have access to their own documents, such as ID or their passport, with the employer having confiscated them Individuals may not have a contract and may not be paid National Minimum Wage or not paid at all Workers are forced to stay in accommodation provided by the employer.
• This accommodation could be overcrowded Individuals could live on site Workers could be transported to and from work, potentially with multiple people in one vehicle The person might not accept money or be afraid to accept payment Workers may work particularly long hours.

Definitions :

• 6.1 Section 52 Modern Slavery Act This places a duty on Local Authorities to identify and refer modern slavery child victims and consenting adult victims through the National Referral Mechanism (NRM) This responsibility identifies a local authority as a First Responder. The Council as a first responder (FR) into the NRM process has a duty to notify the Home Office if anyone working within the council identifies a person with indicators suggesting they may be trafficked or enslaved
• 6.2 Human Trafficking Human trafficking is defined as the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation It is important not to confuse human trafficking with human smuggling. Human smuggling is also called people smuggling. Human smuggling occurs when an individual seeks the help of a facilitator to enter a country illegally, and the relationship between both parties ends once the transaction ends. Many of those who enter the UK illegally do so by this route. Human smuggling is not a form of modern slavery
• 6.3 Turnover “Turnover” means the amount derived from the provision of goods and services falling within the ordinary activities of the commercial organisation or subsidiary undertaking, after deduction of Trade discounts Value added tax Any other taxes based on the amounts so derived (HM Government - 'Transparency in Suppy Chains')
• 6.4 Modern slavery A large number of active organised crime groups are involved in modern slavery. But it is also committed by individual opportunistic perpetrators Modern slavery encompasses slavery, human trafficking, forced and compulsory labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment There are many different characteristics that distinguish slavery from other human rights violations, however only one needs to be present for slavery to exist
• 6.5 Exploitation (Modern Slavery and Human Trafficking) Cultural Exploitation – those manipulated or coerced using religious, social or cultural beliefs e.g., FGM, radicalisation, forced marriage Financial Exploitation – debt bondage; finances controlled by others; financial scams; benefit fraud Modern Slavery – human trafficking; forced labour; domestic servitude; organ harvesting Sexual Exploitation – forced sex work or working in the commercial sex industry (pornography, lap dancing, telephone lines etc.); those manipulated or coerced into sexual activities of any kind for another person’s gain Criminal Exploitation – those manipulated or coerced or trafficked for the purpose of any illegal activity i.e., County Lines/drug trafficking; cuckooing (taking over of a person’s property); forced street crime (shoplifting, begging etc.); cannabis cultivation.

Key Facts – Professionals

• Professionals providing this service should be aware of the following: Where applicable, an annual statement on modern slavery and human trafficking will be published by GLOBAL NORTH LONDON BUSINESS SCHOOL on our website and approved by the senior management team e.g. the board of Directors and signed by a Director Staff will receive training on Modern Slavery Human Trafficking, and be supported by GLOBAL NORTH LONDON BUSINESS SCHOOL if subject to, or reporting of, cases of slavery or human trafficking only staff that have been through robust recruitment procedures will be employed at GLOBAL NORTH LONDON BUSINESS SCHOOL The Modern Slavery Act 2015 details what organisations need to do about slavery and human trafficking If slavery or human trafficking is disclosed to you then this must be shared with the Registered Manager Michael Benson or the police if someone is in immediate danger If there are cases of slavery or human trafficking then the service will share this information with City of London.

Key Facts - People affected by the service

• People affected by this service should be aware of the following: If you are aware of or become part of any acts of modern slavery or human trafficking, this can be reported to GLOBAL NORTH LONDON BUSINESS SCHOOL and the necessary support will be provided You will receive Care from staff who have been through robust recruitment procedures.

Outstanding Practice

• To be ‘ outstanding ’ in this policy area you could provide evidence that: GLOBAL NORTH LONDON BUSINESS SCHOOL regularly audits and conducts thorough due diligence on its supply chain Specific training is provided on slavery and human trafficking The publishing of a statement on slavery and human trafficking even if this is not a legal requirement A very high level of understanding and awareness demonstrated in all areas of the service GLOBAL NORTH LONDON BUSINESS SCHOOL shares its practice in this area with other organisations and is seen as a 'best practice resource.