Capital Training Ltd
Modern Slavery and Human Trafficking Statement

Modern Slavery and Human Trafficking Statement is a response to Section 54(1), part 6 of the Modern Slavery Act 2015 and relates to the activities for the financial year ending 31-3-2022. Capital Training Ltd (The Company, We, us or our) is committed to preventing human trafficking violations in its own operations and in its supply chain. We have zero tolerance for slavery and require our supply chain to comply with our values.

Organisational Structure

Capital Training has business operations in the United Kingdom. We operate in the educational sector and the nature of our supply chain is that we work directly with all our individual suppliers. For more information on the company, please visit our website www.capitaltraining.com.

Policies

We operate a number of internal policies that ensure that we conduct business in an ethical and transparent manner.

  • Recruitment and Selection Policy: We conduct checks on all prospective employees to verify that they are entitled to work in the UK. Certain roles require a Disclosure and Barring Service (DBS) check where employees may be working with vulnerable people. We personally interview every employee in person or by Teams / Zoom.
  • Whistle Blowing Policy: We operate this policy so employees are able to raise concerns about how staff are being treated or practices within our business or supply chain without fear of reprisal.
  • Staff Code of Conduct: We are committed to the fair treatment of all our staff. Our code of conduct reflects our core values and expected behaviors. The code of conduct makes it clear we have a zero-tolerance approach to modern slavery. We ensure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our business, we have adopted the following due diligence procedures.

  • Internal Supplier Audits:
    • This aims to identify and action potential risks to our business and supply chain.
    • Reduce the risk of human slavery occurring in our business or supply chain.
    • Provide protection for whistleblowers.

Risk and Compliance

The company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its supply chain through:

  • Evaluating the slavery and human trafficking risk of each new supplier.

We do not consider that we operate in a high-risk environment because the business operates in a low-risk industry and the supply chain is entirely UK based. We do not tolerate slavery and human trafficking in our supply chain. If we ever found evidence of failure to comply with our policies and procedures by any of our suppliers, we would seek to terminate our relationship with that supplier immediately.

Effectiveness

The company uses Key Performance Indicators (KPIs) to measure its effectiveness and to ensure that slavery or human trafficking is not taking place within its business or supply chain.

  • We carry out a regular annual audit of all our suppliers.

This statement was approved by the board of directors.