Background
Every organisation carrying on a business in the UK with a total annual turnover of £36m (Modern Slavery Act 2015 section 54 (2b)) or more is required to produce a slavery and human trafficking statement for each financial year of the organisation. Whilst Mainstream does not meet this threshold, it aims to be pro-active re the control, identification and reporting of modern slavery and human trafficking.
Our sector and risk
Within Mainstream, we train people to enter or progress their careers within the logistics, warehouse and construction sector, we provide driver training services to the defence sector and we provide agency and recruitment services. We operate in the UK where, compared to many other parts of the world, modern slavery risk is lower and Government activity and regulation is considerable.
Mainstream Group recognises that whilst the education and skills training sector and some of the sectors we support are low risk, slavery and human trafficking remains a hidden blight and readily executable within the recruitment sector. Our aim is to acknowledge our corporate responsibility by alerting staff to the risks, however small.
We understand the modern slavery and human trafficking risk that can occur in product supply chains. We recognise the higher risk products – garments, electronics, textiles and timber. Mainstream Group has very little need or use of these products. The main area of risk is related to garments where we purchase Personal Protective Equipment (PPE) for staff and or learners. We mitigate this risk by purchasing PPE with specific quality marks.
Our policies
In addition to this policy, we maintain other policies which support our approach.
The steps we take
Our safeguarding arrangements set out our commitment to the protection of individuals and their rights. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management are to act upon them. Extracts of our safeguarding arrangements include:
Trafficking and Modern Slavery is a crime and violation of fundamental human rights. It takes various forms, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. Entire families can be trafficked and can often appear to be living normal lives. The National Crime Agency sets out the full National Referral Mechanism (NRM) for identifying, protecting and supporting victims of human trafficking.
Mainstream is fully committed to preventing slavery and human trafficking and to ensuring transparency in our own business and approach with our supply chains, consistent with disclosure obligations under the Modern Slavery Act 2015. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain. We identify and assess potential risk areas when considering taking on new suppliers and regularly review our existing supply chains. We:
Gangs and County Lines (Criminal Exploitation) – Adults, young people, and children becoming involved in gangs are vulnerable to a range of risk taking, grooming and illegal activities including involvement in drug dealing, organised/gang crime, substance misuse, Child Sexual Exploitation, extremist activity and other forms of abuse and criminal activity. Concerns about organised gangs and criminal exploitation should be reported through safeguarding procedures.
Child Sexual Exploitation (CSE) – All staff are expected to understand how some young people and children can be groomed, coerced, and exploited by adults and other young people and some adults may be troubled by historic CSE. Staff report any concerns through the safeguarding reporting system.
Private Fostering is when a child under the age of 16 (or 18 plus with a disability) lives with someone, who is not considered a close relative of the person, for 28 days or more in a year. Examples of this include living with a grandparent, aunt/uncle, sibling or stepparent. It is the law that any Local Authority is made aware of all the children who are being privately fostered as the local authority has a duty to ensure that the child is safe and that the private foster carer has adequate support. If a member of staff is concerned or unsure about private fostering, they must consult with the safeguarding officer.
Our Suppliers Audit Policy sets out our arrangements for new suppliers. With new suppliers, if they are considered to be of material risk in terms of Impact of supplier failure on our business the department manager placing the first order discusses the supplier selection with the department director and then the department manager will monitor quality of supply until the first six monthly supplier audit check. To support this, all purchase invoices are approved by department managers via our paperless system which cross matches to purchase orders, this provides an ongoing system whereby any supply failures can result in payments be withheld whilst a supplier is reviewed. Mainstream is not large and department directors will always be aware of material supplier failure as they happen.
Effectiveness of our approach
In June 2023, Mainstream’s provision was subject to full inspection by Ofsted. The inspectors judged: “The arrangements for safeguarding are effective. Leaders use appropriate safeguarding policies and procedures to keep learners and apprentices safe. They use suitable systems to identify, record and monitor concerns. The experienced designated safeguarding lead ensures that staff complete annual safeguarding training and know how to report concerns. Staff ensure that learners who experience welfare problems, such as risk of homelessness, are well supported and referred to the relevant agencies. Leaders ensure that thorough risk assessments are completed of high-risk prisoners before enrolling them on courses. As a result, staff maintain the safety of all learners effectively”. Our safeguarding records show no modern slavery or trafficking concerns recorded.
Our internal Suppliers Audit Policy and process (QMS605) forms part of our Quality Management System (QMS). Our QMS is subject to annual certification assessment to ISO9001 standards. Our most recent assessment was in August 2024 and re-certification was achieved with zero non-conformances.
Training and capacity building
All staff are made aware via induction and regular updates of safeguarding training issues related to trafficking and modern slavery.
All staff have access to all policies and procedures and understand they are expected to follow them at all times. All aspects of our quality management system are subjected to internal and external audits.
We monitor updates from walkfree.org to ensure our knowledge remains current.