The Girls’ Day School Trust (GDST) is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. This statement sets out the steps the GDST is taking, during the financial year 1 September 2018 to 31 August 2019, to understand potential modern slavery risks within its business, and to ensure that there is no slavery or human trafficking taking place in its business and its supply chains.
Organisational structure and supply chains
The GDST is the UK’s leading network of independent girls’ schools, with 23 schools and 2 academies throughout England and Wales. It was founded in 1872 and educates 19,000 pupils and employs 3,500 staff.
As the GDST is a charity, procurement of quality goods and services has always been an important part of ensuring charitable funds are carefully spent. Supply chains utilised by the GDST currently include uniform, catering, caretaking and grounds maintenance, cleaning, furniture and equipment, ICT hardware and construction.
The GDST has considered which of its supply chains could be at a high risk of slavery or human trafficking. Regard was given to supply chains which are high risk, originate outside the UK, and guidance from ISBA (The Independent Schools’ Bursars Association) which identifies high risk supply chains for schools as catering, stationery and uniform.
As part of the GDST’s initiative to identify and mitigate the risk of slavery and human trafficking in supply chains, the GDST carries out stringent due diligence on new suppliers. This includes:
Obtaining general information on supplier companies and understanding their corporate structure
Assessing supplier financial stability by reviewing recent and previous company accounts
Ensuring suppliers are able to provide adequate assurances of their own commitment to preventing modern slavery and human trafficking
Ensuring suppliers are able to provide relevant health and safety checks
Ensuring suppliers on GDST framework contracts are ISO 9001 compliant, and provide details of their quality assurance systems and policies across a number of areas – this is to ensure high standards particularly in relation to working conditions and people
Obtaining details of supplier policies for the purchase of consumables
Requiring suppliers to pay their staff, who are working on GDST sites, the Living wage, as defined by the Living Wage Foundation.
In 2017, the GDST published an internal Anti-Slavery policy, which demonstrates its commitment to act ethically and with integrity in business relationships. The policy also demonstrates the GDST’s commitment to having effective systems in place to ensure slavery and human trafficking are not taking place within its business and its supply chains.
The GDST’s Anti-Slavery policy makes reference to other relevant and longstanding GDST policies, such as its Whistle-blowing policy, Procurement policy, Dignity at Work policy, Pay policy and Disciplinary Policy. In turn, these policies are carefully monitored and independently audited on a regular basis.
The GDST is confident that, together, these policies effectively mitigate the risk of slavery and human trafficking taking place within its business or supply chains, and provide support to staff should they have any concerns.
The GDST’s Anti-Slavery policy is reviewed annually and supplemented with details of additional steps that can be taken by staff to ensure there is no slavery or human trafficking in the GDST’s business or supply chains.
Progress this financial year
In its May 2018 Anti-Slavery Statement, the GDST identified a number of steps that it would consider implementing in future. The GDST has, this financial year, implemented a number of these steps. Such as ensuring a number of its contracts with suppliers contain anti-slavery and human trafficking clauses, and creating new frameworks and preferred supplier lists for 9 different categories. Importantly, those supply chains which are identified as being at a higher risk of modern slavery offences in the education sector fall within the scope of these new frameworks and preferred supplier lists.
Future steps and Key Performance Indicators
The GDST is committed to improving its practices to ensure that its business and supply chains are free from slavery and human trafficking. Some of the additional steps that the GDST will make progress towards implementing in future are:
Assessing and commenting on the GDST’s effectiveness in ensuring that slavery and human trafficking are not taking place in its business or supply chains. The GDST would use appropriate key performance indicators to do this.
Enhanced due diligence, specific to slavery and human trafficking.
Enhanced due diligence on existing suppliers, rather than on new suppliers only.
Regular risk assessments on supply chains, including mapping out GDST supply chains identified as being at a higher risk of modern slavery offences in the education sector.
Proactive engagement with high risk suppliers to obtain more detail on the entire supply chain.
Staff training to raise awareness of slavery and human trafficking, especially from a procurement and employment perspective.
Increased use of ethical suppliers.
Maximised use of Living Wage Foundation pay rates across large contracts with a high proportion of staff costs.
Ensuring that the GDST’s Anti-Slavery Statements from previous years are available on its website to allow the public to compare the GDST’s statements between years and monitor the GDST’s progress over time.
The Girls’ Day School Trust make this statement pursuant to section 54(1) of the Modern Slavery Act 2015, for its financial year ending 2019. This statement has been approved by The Girls’ Day School Trust’s board of directors who will review and update it annually.
Juliet Humphreys, Director (review date 17th May 2020)