Modern Slavery Policy

Policy Reference Number	PT/MS/V2

Date of approval	April 2025
Next Review Date	April 2026

Introduction

Primed Talent Ltd recognises modern slavery as a heinous crime and a grave violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour, and human trafficking, all of which exploit individuals for personal or commercial gain.

Primed Talent Ltd maintains a zero-tolerance approach to modern slavery in all its forms and is committed to operating ethically, transparently, and in full compliance with the UK Modern Slavery Act 2015 and other relevant legislation.

Purpose and Aims

The purpose of this policy is to outline the measures Primed Talent Ltd takes to prevent the risk of modern slavery occurring within its operations or supply chains.

The policy aims to:

Embed processes to detect, prevent, and respond to risks of modern slavery.
Promote ethical standards and compliance across all business functions.
Provide guidance to employees, suppliers, and partners on recognising and reporting concerns.
Demonstrate our commitment to the highest ethical standards and responsible sourcing.

Scope

This policy applies to:

All employees of Primed Talent Ltd, including contractors and temporary staff.
All suppliers, subcontractors, and business partners engaged by the company.
All geographical locations in which Primed Talent Ltd operates or has supply chains.

Policy Statement

Primed Talent Ltd will apply the following principles to uphold our zero-tolerance stance:

4.1. Organisational Structure and Supply Chains
Primed Talent Ltd delivers business, technical, and digital skills training across the UK, with clients in the public and private sectors. Our supply chain includes:

Professional services firms
Utility and facilities providers
Technology platform providers
Independent trainers and consultants
Outsourced service providers

4.2. Internal Policies and Governance
We have established the following policies to support modern slavery prevention:

Whistleblowing Policy – confidential channels for reporting concerns
Code of Conduct – behavioural expectations for all employees and contractors
Supplier Code of Conduct – outlining supplier responsibilities on modern slavery compliance
Recruitment Policy – promoting fair and transparent hiring

These are reviewed annually and reinforced through staff training and supplier contracts.

4.3. Due Diligence and Supplier Engagement
We carry out due diligence to assess and manage risk, including:

Mandatory supplier risk assessments and questionnaires
Inclusion of anti-slavery contractual clauses in all agreements
Regular audits or reviews for high-risk suppliers
Onboarding controls to verify third-party compliance

4.4. Risk Assessment and Management
While we assess our risk as low due to the nature of our services and UK operations, we regularly evaluate:

Supplier geographies and sectors
Labour practices and employment models
Subcontracting and outsourcing practices

Non-compliance may result in termination of business relationships.

4.5. Staff Awareness and Training
All employees are briefed on the signs of modern slavery and their duty to prevent it. Additional training is provided for those involved in procurement and recruitment.

4.6. Reporting and Whistleblowing
We encourage staff and stakeholders to report any suspicions of modern slavery via our internal whistleblowing procedure. All reports are handled confidentially and in line with our governance policies.

4.7. Continuous Improvement
We commit to ongoing improvements through policy reviews, supplier evaluations, and legal compliance updates. The policy will be reviewed annually and updated as required.

Definitions

Modern Slavery – Encompasses slavery, servitude, forced labour, and human trafficking.
Supply Chain – All third-party entities providing goods or services to Primed Talent Ltd.
Whistleblowing – Reporting concerns about wrongdoing, malpractice, or unethical behaviour.

Responsibilities

All employees, contractors, and suppliers are responsible for:

Understanding and adhering to this policy.
Reporting any suspicions or incidents of modern slavery.
Completing required training.

The Managing Director has overall accountability for policy implementation.
The Compliance and Operations team is responsible for monitoring, training, and supplier due diligence.

References

Modern Slavery Act 2015
Primed Talent Ltd Whistleblowing Policy
Primed Talent Ltd Code of Conduct
Primed Talent Ltd Recruitment Policy
Supplier Code of Conduct

Document Control and Review

Field	Detail
Policy Title	Modern Slavery Policy
Policy Reference Number	PT/MS/V2
Approved by	Managing Director
Date Approved	April 2025
Next Review Date	April 2026