Modern Slavery Act Statement 2018-2019
This statement is The Prince’s Trust’s voluntary modern slavery and human trafficking statement relating to section 54 of the Modern Slavery Act 2015 (“the Act”).
We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that slavery or human trafficking is not taking place in our business or in our supply chains.
The Prince’s Trust is a company incorporated by Royal Charter and a registered charity in (1) England and Wales and (2) Scotland. We work with young people in the United Kingdom to develop the confidence to live, to learn and to earn. Much of our support for young people is delivered through partner organisations and with the aid of volunteers. We also work with a diverse range of sponsors, funders and suppliers who will have their own suppliers, sub-contractors and partners.
The Prince’s Trust Group includes the work of The Prince’s Trust, together with a network of other organisations carrying out work in other countries:
- Prince’s Trust International (PTI)
- Prince’s Trust Canada (PTC)
- Prince’s Trust Australia (PTA)
- Prince’s Trust New Zealand (PTNZ)
- Prince’s Trust America (PTAm)
The Prince’s Trust is the sole member of PTI, PTC, PTA and PTAm, and is the sole settlor of the PTNZ trust.
The Prince’s Trust’s commercial activities are dealt with by its wholly owned subsidiary, Prince’s Trust Trading Limited, a UK registered company.
None of the entities in The Prince’s Trust Group (whether separately or combined) have an annual turnover of £36 million from the provision of goods and services (as set out in the Act). Therefore, although we are not required to make a modern slavery statement under the Act, The Prince’s Trust is choosing to voluntarily comply as we believe it is incumbent upon all organisations to do what they can to tackle modern slavery and human trafficking. This statement is intended to show our commitment to ethical trading principles and to set out the steps we are taking in our business and in our supply chains. In relation to overseas entities, we have set out our expectation that they procure goods and services in a transparent way, having regard to the Act.
We have assessed the main relevant areas of The Prince’s Trust’s business as follows:
- Procurement of goods and services to support our operations, including contract cleaning services, merchandise, office supplies and equipment, travel services, and IT delivery and support. This would also cover the use and recruitment of agency workers, temporary workers and consultants.
- Use of delivery partners to carry out our programmes, particularly in relation to programmes where programme participants may obtain temporary or permanent employment as a result of their participation.
We have a number of policies in place to assist us in our in ensuring compliance with the Act:
- Whistleblowing Policy;
- Anti-bribery Policy;
- Fraud and Theft Policy;
- Anti-Money Laundering and Terrorism Policy;
- Ethical Fundraising Policy, which includes due diligence requirements on organisations/individuals;
- Procurement Policy, to ensure that appropriate due diligence is undertaken and contract wording is included for suppliers, and
- Safeguarding Policy, which sets out standards for our staff and procedures regarding reporting of suspected abuse.
We are committed to ensuring that value for money does not compromise our obligations or our commitment to the Act. Our commitment to the eradication of modern slavery is shown in a number of actions which are undertaken by us:
- Risk management plays a key part in the identification, management and escalation of risks within the supply chain. This process enables the Boards of the Group entities to evaluate compliance with the Act within each entity.
- The policies listed above have all been updated or introduced in the last year. They are scheduled for review at least every two years, to ensure they are up to date and relevant to the work that we do.
- We have amended our template contracts with partners carrying out our programmes to include wording regarding modern slavery.
- We have carried out an initial review of what we expect of suppliers relating to our operations (eg contract cleaning, office and IT suppliers), and have standard wording setting out our standards and expectations. We have contacted the main organisations who we procure marketing or merchandise goods or services from, particularly those with onward supply chains, and ensured that variation letters are signed where existing contracts do not contain appropriate wording regarding modern slavery.
- We carry out appropriate due diligence (in line with our Ethical Fundraising Policy) on those organisations/individuals who wish to fundraise with or for us.
For work carried out by Prince’s Trust International, we have a due diligence process for the appointment of new delivery partners and when scoping new countries or territories.
We intend to take the following further steps to combat slavery and human trafficking:
We will carry on our work to review our contract arrangements with programme partners to ensure that any new or renewed contracts contain appropriate wording regarding modern slavery.
We will continue to increase our safeguards in our supply chains. Initial work will focus on those suppliers where we assess there is the greatest potential risk.
- We will ensure that recruitment agencies on our preferred supplier list are reputable agencies – and require that all those on our preferred supplier list have appropriate modern slavery provisions.
- We will continue to review our behavioural framework for staff and ensure that there are clear mechanisms in place to signpost staff and volunteers to additional policies and resources.
Effectiveness in combatting slavery and human trafficking
We will continue to keep our effectiveness under review and to make changes to our operations and our ongoing work if they are not proving to be as effective as they ought to be.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we recognise the importance of staff training. In spring 2018 all staff were required to complete mandatory safeguarding training, which included a section on child trafficking. This training is also mandatory for all new staff. Over the next year we will continue to seek improvements to training processes for staff and volunteers, including widening the scope of training to include modern slavery as well as child trafficking.
This voluntary slavery and human trafficking statement is made in connection with section 54(1) of the Modern Slavery Act 2015, for the financial year ending 31 March 2019. It was approved by The Prince’s Trust Council on 21 March 2019.
On behalf of The Prince’s Trust
Date 26 March 2019