Modern Day Slavery Policy

Introduction

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 are committed to improving our practices to combat slavery and human trafficking.

iTrain has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business.

This policy is made pursuant to section 54(1) of the Modern Slavery Act 2015 ("the Act") and constitutes iTrain's response to the requirements of the Act. It sets out the steps that iTrain has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business.

Organisational Structure

iTrain provides bespoke training, project management, roll-out support and consultancy services to clients in the legal sector employing more than twenty-five members of staff. We are based nationally but are involved across Europe.

Policy Aim

The aim of this policy is to demonstrate that the Company follows good practice and all reasonable steps are taken to prevent slavery and human trafficking.

All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking, with the Human Resources department taking lead responsibility for compliance. The Company has risk assessment processes in place detailing risk management, safeguarding and whistleblowing. We are aware of the responsibility we have towards our employees and clients and encourage employees to report any concerns.

What is modern slavery?

The offence of modern slavery includes subjecting someone to slavery or servitude, forced or compulsory labour, including child labour, and human trafficking, often breaching human rights law, employment law and health and safety regulations, harsh and inhuman treatment, and exploitatively low pay and long hours.

Someone is in slavery if they are:

• Forced to work either through coercion, mental or physical.
• Owned or controlled by an 'employer' through mental or physical abuse, or the threat of.
• Dehumanised by being treated as a commodity or bought and sold as 'property'.
• Physically constrained or have unlawful restrictions placed on their freedom of movement

Our due diligence processes on slavery and human trafficking

To identify and mitigate the risks of modern slavery and human trafficking in our own business we:

• Complete pre-employment checks on staff we employ, confirming their identities and right to work in the United Kingdom.
• Follow government guidelines to ensure staff receive fair pay rates and contractual terms.

Training and Recruitment

iTrain ensures that staff receive appropriate training to make sure that they have a good understanding of the risks of modern slavery and human trafficking in our business.

iTrain will require its business partners to adhere to health, safety and employment laws in the location in which they operate, and to ensure that they put in place measures to prevent and address modern slavery. If we become aware of any facts to suggest that one of our partners engage in modern slavery, we will thoroughly investigate, and where appropriate, terminate the relationship and report to the responsible national or international authorities.