Commencing 29th October 2015, medium to large-sized companies are required to make a statement on their slavery and human trafficking policy for each financial year in accordance with Section 54 of the Modern Slavery Act 2015 (“The Act”).
This is Tribal Group plc’s (Tribal) slavery and human trafficking statement for the last financial year ended 31 December 2020 and current as of 01 May 2021.
The purpose of the Act is to eradicate modern slavery. This encompasses human trafficking, slavery, forced labour and servitude. As a commercial organisation, we are required to publish an annual statement setting out the steps that we are taking to prevent modern slavery in our business and in our supply chain. The Act has the effect of exposing companies to the common practices of contract governance through the transparency the Act imposes on a company’s supply chains, policies and procedures. The Act also seeks to highlight the need to be alert to the risks the business faces, including its wider supply chain. Staff are expected to report concerns and management are expected to act upon them.
Tribal provides a wide range of products and services that support the delivery of education services around the world, including the development and implementation of software, supporting adult learning and careers development, and providing schools inspections and improvement services. As a world-class company, our mission is to empower the world of education. Our clients use our expertise, software and services to assist with student enrolment, assessment and reporting obligations. These core functions underpin student success. We operate in the UK, Europe, Australia, New Zealand, Canada, United States, Middle East and South-East Asia.
Tribal's group structure is detailed in the Corporate Entities Table appended below which includes its overseas subsidiaries and branches. The Group's turnover is £73 million per annum (2020 Annual Report and Accounts for the year ended 31 December 2020).
As a global business, Tribal has clients, suppliers, sub-contractors, associates, and employees who are based within and outside the UK. Tribal recognises the need to ensure compliance with the provisions of the Act beyond the UK and has therefore introduced changes across the entire business in order to comply with its statutory obligations.
The majority of Tribal's supply chain is based in low-risk countries where forms of modern slavery are not prevalent. Tribal's supply chains comprise mainly human resources who perform skilled services, whether they be employees, sub-contractors, associates, or agents. Traditionally, Tribal also sources software from third parties to facilitate the production of its own products and services.
Tribal's business model is substantially the development, licence, implementation, hosting and support of its own software products. It also conducts audits of educational institutions, undertakes surveys and research of educational institutions, and produces benchmark reports based on its industry knowledge and expertise.
Tribal's due diligence processes have been tightened in relation to the review, negotiation, and approval of commercial contracts. Tribal has a Delegation of Authority Policy (DOA Policy) in place, which is reviewed annually, or more frequently if required. This requires all contracts to be reviewed, negotiated, and signed off by the Global Legal Team and the Global Finance Team. These steps help to ensure that all contracts are reviewed for compliance with all Tribal governance policies, including its Anti-Slavery Policy. These steps help ensure that the contracts we enter into through our subsidiaries contain provisions that conform with the Act. These steps ensure compliance with suitable equivalent statutory provisions in relation to contracts that are subject to the laws of a foreign jurisdiction.
Tribal has a zero-tolerance approach to modern slavery and is fully committed to preventing slavery and human trafficking via its business activities. Tribal is also committed to ensuring there is transparency in its activities and its approach to tackling modern slavery throughout our supply chains, consistent with the disclosure obligations of the Modern Slavery Act 2015. Tribal has several policies/procedures/practices relating to Slavery and Human trafficking, including:
Tribal recognises that in order to manage its compliance with the Act, especially throughout its non-UK operations, it is essential to have and to maintain appropriate processes which identify and mitigate related risk.
The cornerstone for Tribal has been raising awareness of slavery and human trafficking and identifying any processes we can implement to identify any unusual business behaviour. As with any risk management system, this is a continuing process.
The Board of Directors and senior management recognise that their support of all governance policies is an essential requirement to foster positive and appropriate behaviour within the organisation. This approach also influences suppliers and subcontractors, particularly when risk assessment of their operations is undertaken comprehensively.
Tribal has a Global Supplier Management Framework which sets out the following guidance:
Tribal requests information from prospective suppliers to ensure that they meet certain criteria including (but not limited to): Health and Safety; International Organization for Standardization (“ISO”) certifications; insurances; equality and diversity and environmental policies; policies evidencing compliance with the terms of the Act. These criteria are used as part of the process to select suppliers and we request updated versions of these key documents/certifications on an annual basis. The specific question we ask is: What steps does your company take to ensure compliance with the Modern Slavery Act 2015?
Tribal operates an annual programme of corporate compliance training which is mandatory for all staff. This includes training on the terms of the Act, how we comply with our responsibilities under it, and being aware of factors that the Act is intended to address, such as: human trafficking; the ability of an individual to choose employment; a safe working environment; prohibition on the use of child labour; non-discrimination; working time directive; and that no harsh or inhuman treatment is allowed in the workplace.
Tribal’s Global Governance Group report to the Board of Directors monthly. An aspect of their reporting covers compliance with the Act. The Global Governance Group uses key performance indicators to measure Tribal's effectiveness in tackling slavery and human trafficking within the business and its supply chain:
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Tribal Group’s slavery and human trafficking statement for the current financial year. It has been reviewed and approved by the Board of Directors.
Chief Executive Officer