The Girls’ Day School Trust – Anti-Slavery Statement
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- Introduction
The Girls’ Day School Trust (GDST) continues to be 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 has been updated to reflect the progress made by the GDST during the financial year 1 September 2020 to 31 August 2021. It sets out the steps the GDST is taking to understand potential modern slavery risks within its business, and to endeavour to ensure that there is no slavery or human trafficking taking place in its business or 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 3,700 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, agencies for the recruitment of international students, construction and educational supplies.
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 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.
- Due diligence
As part of the GDST’s initiative to identify and mitigate the risk of slavery and human trafficking in supply chains, the GDST adopts a risk-based approach to due diligence on new suppliers, with a focus on those identified as carrying the greatest exposure of risk whether due to geographic area, industry sector or value of spend. The steps taken are tailored to the individual supplier and can include:
- 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 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.
- Relevant policies
The GDST has appropriate policies in place to ensure that there is no modern slavery or human trafficking in its supply chain or business. These policies are regularly reviewed and updated.
The key policy is the GDST’s internal Anti-Modern Slavery and Human Trafficking policy, which was updated in the course of the 2021/22 financial year, and which demonstrates the organisation’s 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 endeavour 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, including its Whistle-blowing policy, Procurement policy, Dignity at Work policy, Pay policy, Anti-money laundering policy and Safeguarding policy. In turn, these policies are carefully monitored, and the whistleblowing policy and fraud policy are reviewed by our external auditors.
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.
- Progress this financial year
In its May 2020 Anti-Slavery Statement, the GDST identified a number of steps that it would consider implementing in future. The Coronavirus pandemic has impacted upon the implementation of these actions and meant that the publication has occurred within the extended timeframe provided by the Government. Good progress has, however, been made and a number of steps have been implemented. These include:
- Enhanced due diligence, specific to slavery and human trafficking, in relation to new suppliers identified as high risk by our Procurement team.
- Risk assessments on supply chains and further exploration of supply chains identified in practice as being at higher risk of modern slavery offences in the education sector.
- Maximised use of Living Wage Foundation pay rates across large contracts with a high proportion of staff costs, systematically imposed upon suppliers through the tendering process and our contract wording.
- Updating preferred supplier lists and framework agreements when they come up for re-tender to include contractual clauses requiring compliance with anti-slavery laws specifically, as well as more generally with all applicable legal requirements.
- Requesting anti-slavery declarations from new high-risk/high-value suppliers.
- Including in any new high-risk/high-value contracts / contract variations an anti-slavery clause in line with the Trust anti-slavery policy (which allows for the Trust to audit suppliers for compliance).
- Increasing due diligence in relation to suppliers for high-risk/high-value contracts, including drawing attention to our anti-slavery policy and anti-slavery contractual provisions when tendering for services and inviting potential suppliers’ comments on anticipated ability to comply.
- Reviewing and updating the Trust’s safeguarding procedures to ensure that they adequately address any modern-slavery risks with regard to the recruitment of international students.
- The Coronavirus pandemic
The GDST has taken steps to ensure that it can continue to identify and address the risks of modern slavery in its operations and supply chains during the coronavirus pandemic. These steps have included:
- Adopting a coronavirus risk assessment at the outset of the pandemic and ensuring that relevant local or national government policies were implemented within the organisation. Steps taken included adopting social distancing measures, allowing for homeworking, providing online training, carrying out lateral flow tests and paying statutory sick pay in order to prevent the spread of coronavirus.
- Ensuring that suppliers were engaged with and that we adhered to agreed payment terms with suppliers to ensure that workers in supply chains received payment for work they had already completed.
- All GDST workers continued to be able to access grievance procedures as a means of raising any coronavirus-related concerns if required and existing policies and procedures were adapted as necessary to enable this.
- The existing and rigorous recruitment checks that the organisation employs, continued to be maintained with appropriate modifications for remote working where necessary (i.e. passports were initially checked via video calls).
- Future steps and objectives
The GDST is committed to continually 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 would like to progress towards implementing in future are:
- More regular risk assessments on existing supply chains.
- 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.
- Specifically reviewing the arrangements that the Trust has in place with agencies for the recruitment of overseas students to ensure that these arrangements address modern slavery risk.
- Working with GDST schools to consider how the consideration of anti-slavery can be embedded into their educational provision.
- Implementing additional controls that will ensure GDST schools fully consider anti-modern slavery risk when appointing suppliers. These checks can then be audited as part of the GDST’s process of internal school audits.
- Board approval
The Girls’ Day School Trust make this statement pursuant to section 54(1) of the Modern Slavery Act 2015, for its financial year ending 2021. This statement has been approved by The Girls’ Day School Trust’s board of directors who will review and update it annually.
Juliet Humphries, Director (review date September 2022)
