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Introduction

Â鶹´«Ã½ (ETF) is committed to addressing modern slavery and human trafficking within our operations and supply chains. We are dedicated to ethically and with integrity in all relationships, enforcing a risk-based approach with processes to combat slavery and human trafficking across our corporate and charitable activities. This commitment extends to all our suppliers and aim to work only with those who share our values.

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes ETF’s annual Modern Slavery Statement for the financial year 1 April 2025 to 31 March 2026.

Organisational Structure and Supply Chains

Established in August 2013, ETF is the government-backed, sector-led workforce development body for the Further Education (FE) and Training sector in England. We support teachers and leaders to achieve their professional development goals, ultimately benefitting learners and employers and contributing to economic growth.

We are the guardian of the Professional Â鶹´«Ã½ for the sector and the professional membership body. ETF is a registered charity focused on improving education and training for learners aged 14 and over by empowering sector professionals. Our operations are currently limited to England.

Risk Assessment

ETF conducts annual risk assessments across our supply base and procurement activity, focusing on:

·&²Ô²ú²õ±è;ÌýÌýÌýÌýÌýÌýÌý The type of goods, works, or services provided.

·ÌýÌýÌýÌýÌýÌýÌýÌý The geographical location of suppliers and their supply chains

·ÌýÌýÌýÌýÌýÌýÌýÌý The supplier’s workforce practices and subcontracting arrangements (if applicable)

Due Diligence

For activities identified as non low-risk, ETF applies a range of measures based on the nature, size, and scale of the procurement. These may include:

·ÌýÌýÌýÌýÌýÌýÌýÌý Requiring suppliers to commit to ETF’s relevant policies and procedures

·ÌýÌýÌýÌýÌýÌýÌýÌý Reviewing the supplier’s Modern Slavery Statement (where applicable)

·ÌýÌýÌýÌýÌýÌýÌýÌý Requesting evidence of how the supplier mitigates modern slavery risks and complies with ETF contract terms.

In 2025–26, ETF will explore due diligence approaches for low-risk suppliers and spend areas, taking into account:

·ÌýÌýÌýÌýÌýÌýÌýÌý Proportional mitigation strategies

·ÌýÌýÌýÌýÌýÌýÌýÌý Resource requirements versus impact

·ÌýÌýÌýÌýÌýÌýÌýÌý Minimising barriers for SMEs

Terms and Conditions

ETF’s standard contract terms include specific clauses prohibiting modern slavery and human trafficking and require suppliers to uphold relevant legal and ethical standards.

Existing Suppliers

We regularly review supply risk throughout the contract lifecycle.
If a supplier is found to be in serious breach of ETF’s Supplier Code of Conduct, sanctions, including contract termination may be applied.

High-Risk Activities

Activities considered high risk for slavery or human trafficking are identified through our due diligence processes and addressed accordingly.

Relevant Policies

ETF has implemented several policies to support the identification and mitigation of modern slavery and human trafficking risks:

·ÌýÌýÌýÌýÌýÌýÌýÌý Recruitment Procedure (Agency Workers):
ÌýETF only works with specified, reputable employment agencies and verifies their practices before accepting workers.

·ÌýÌýÌýÌýÌýÌýÌýÌý Commissioning and Procurement Policy:
ÌýRequires Suppliers to uphold ethical standards, provide safe working conditions, and act within the law.

·ÌýÌýÌýÌýÌýÌýÌýÌý Income Management Policy:
ÌýSets guidelines to ensure consistent contract execution and financial performance, while mitigating financial risk.

·ÌýÌýÌýÌýÌýÌýÌýÌý Whistleblowing Policy:
ÌýEncourages staff, Suppliers, and stakeholders to report concerns related to ETF or its supply chains, including suspected modern slavery. The policy ensures disclosures can be made safely and without fear of retaliation.

·ÌýÌýÌýÌýÌýÌýÌýÌý Modern Slavery and Human Trafficking Policy:
ÌýUnderpins this statement and communicates ETF’s zero-tolerance approach to modern slavery, outlining due diligence expectations and reporting procedures.

·ÌýÌýÌýÌýÌýÌýÌýÌý Anti-Bribery Policy:
ÌýReinforces ETF’s commitment to fair and transparent practices. Linked to our Hospitality and Gifts Policy, it defines what constitutes bribery and outlines preventative measures.

·ÌýÌýÌýÌýÌýÌýÌýÌý Employee Code of Conduct and Â鶹´«Ã½ of Behaviour Policy:
ÌýDescribes expectations for staff conduct and ethical behaviour, including how we manage relationships with Suppliers.

·ÌýÌýÌýÌýÌýÌýÌýÌý ETF Values and Behaviours:
ÌýOur values—Responsive, Inclusive, Expert, Trustworthy, and Strive for Excellence—inform our approach to working with Suppliers and reflect our organisational culture.

Responsibilities

Policy ownership and governance responsibilities include:

ETF’s policy governance framework includes:

·ÌýÌýÌýÌýÌýÌýÌýÌý Accountability: Each policy names the responsible Director, author, reviewer, approver, and a summary of updates

·ÌýÌýÌýÌýÌýÌýÌýÌý Approvals:

´ÇÌýÌý Major updates: Approved by the ETF Board or Senior Leadership Team

´ÇÌýÌý Minor updates: Approved by the relevant Director.

·ÌýÌýÌýÌýÌýÌýÌýÌý Board oversight: All policies are shared with the Board for information.

·ÌýÌýÌýÌýÌýÌýÌýÌý Communication:

´ÇÌýÌý Staff are expected to comply, challenge, or report non-compliance as appropriate.

´ÇÌýÌý Some policies are targeted to specific roles (e.g. line managers)

·ÌýÌýÌýÌýÌýÌýÌý Review cycle: Policies are regularly reviewed for accuracy and compliance

Training

ETF aligns its procurement practices with the Chartered Institute of Procurement and Supply’s Code of Ethics. We ensure that relevant staff receive training and guidance on identifying, preventing, and responding to modern slavery and human trafficking risks.

Approval

This modern Slavery Statement was approved on 6^th June 2025 by Chair’s action.

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Download the Modern Slavery Statement.