Modern slavery statement - E-ACT
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Modern slavery statement
E-ACT Modern Slavery Statement 2023 – 2024
This statement is made on behalf of the E-ACT Multi-Academy Trust (company number 06526376) pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. This statement relates to actions and activities during the year Sept 2023 – August 2024.
E-ACT recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is committed to preventing slavery and human trafficking within its activities and to ensuring that its
supply chains are free from slavery and human trafficking.
This statement has been approved by the Board of Trustees and is published on the Trust’s website in accordance with section 54(7) of the Modern Slavery Act 2015. It will be reviewed and updated annually.
This statement sets out E-ACT’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its business and supply chains.
Structure, business, and supply chains
E-ACT is a national multi-academy trust (MAT), working within some of the most economically deprived areas of
the country. The list of our academies can be found on our E-ACT website.
E-ACT has two principal areas of operations:
A national level which oversees the organisation as a whole
A local level – e.g. an individual academy
Our suppliers are UK based, and key supply areas cover catering, maintenance/repairs, agency staff and cleaning.
The Trust operates solely within the United Kingdom. While this reduces exposure to some higher-risk jurisdictions, we recognise that modern slavery risks can still arise through outsourced services, agency staffing, estates works, catering and cleaning provision. These areas form the focus of our risk-based due diligence.
Our approach
We work to the highest professional standards and comply with all laws, regulations, and rules relevant to our business. We expect the same exacting standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We act ethically and with integrity in all our charitable and business relations.
Policies, documentation, and key relationships
The following key policies and documentation detail our approach to protecting our pupils and staff from modern slavery and ensuring our supply chains are free from modern slavery.
Procurement and Contracts Policy
Concerns and Complaints Policy
Whistleblowing Policy and Procedure
Single Central Record (SCR), Personnel Files and Safer Recruitment Policy
Child Protection and Safeguarding Policy
Code of Conduct
Supplier terms and conditions
In addition, we work closely with the National Joint Council (NJC) to help reduce risk by improving employee working and pay practices.
Our Audit & Risk Committee (ARC) has overall oversight of the process and practices embedded within E-ACT to reduce Modern Slavery and in ensuring our supply chains, which rely on people, can demonstrate adherence with local and national laws and regulations, including paying the minimum wage. The members of the Committee work together with the Personnel Committee as appropriate on these areas.
Identifying and addressing risks
The Trust applies a risk-based approach to identifying and addressing modern slavery risks. This includes consideration of sector risk, workforce characteristics, contract value, length of supply chain and safeguarding vulnerability.
We recognise as a Trust that there are two main avenues of risk through which modern slavery could impact EACT. The first is through matters of a safeguarding nature which covers child sex exploitation or human trafficking
which can directly impact our pupils. This also potentially affects the staff of our contractors. The second is our supply chain and the vendors we contract with.
Safeguarding
We take safeguarding seriously in upholding our statutory duties and striving to safeguard staff and pupils through a culture of safeguarding in everything we do. We have a National Director of Safeguarding, Attendance and Behaviour, supported by a Trust Safeguarding Lead as well as Designated Safeguarding Leads in every academy.
Collectively these colleagues work together to implement policy and secure excellence in safeguarding practice across the Trust. These colleagues are highly experienced in this area and model excellent practice for all staff.
Through their leadership, each academy proactively works with the local authorities, the local safeguarding partnerships, the LADO (Local Authority Designated Officer) and local stakeholders to combat safeguarding issues, including child sexual exploitation and human trafficking. Their good practice is shared amongst the academies and the focus of safeguarding training always includes training on early identification of those at risk of exploitation.
The quality and impact of our safeguarding practice is reviewed at every level of Trust governance. Safeguarding policy and practice is reviewed at every Academy Review Day, and Directors provide assurance to the Executive Leadership Team at the Challenge days. In addition, the Chief Executive Officer meets regularly with our National Director of Attendance, Behaviour and Safeguarding, who also provides regular reports to both the Education Committee and full Board.
Statutory safeguarding practices and impact on keeping children safe are formally reviewed by the national safeguarding team and audited through the work of the Internal Audit Team. This is also quality assured by the National Director of Attendance, Behaviour and Safeguarding.
Safeguarding is an agenda item at every Trustees Education Committee Meeting with an update then provided from that meeting to the full Trust Board. We have a named Trustee with portfolio responsibility for Safeguarding.
Our E-ACT Child Protection and Safeguarding Policy is reviewed annually by the Executive Leadership Team and approved by the Board of Trustees. It is fully compliant with all statutory requirements and guidance set out in Keeping Children Safe in Education (DfE).
Due to the geographical spread of our academies, each academy Designated Safeguarding Lead is required to understand the local safeguarding context. This is included within the policy for each academy and published on each academy website.
Supply chain
E-ACT’s procurement regulations set out the requirements we have regarding engagement with suppliers. Our suppliers are required to comply with all local and national laws and regulations. This includes paying their staff the minimum wage, and any on-site staff passing a DBS (Disclosure & Barring Service) check. We publish our standard terms and conditions to ensure providers looking to contract with us are aware of our standards. Should suppliers fail to meet our minimum requirements, or be unwilling to make any changes, we may cease to trade with them.
Procurement is subject to internal audit review, as well as assessed by our external auditors annually. Frameworks via public sector buying organisations are considered for all tenders and these meet the requirements of the Modern Slavery Act 2015 by default. In the event we opt not to use an existing framework all tenders go through Head of Procurement at which point the modern slavery risk will be considered and incorporated into the tender evaluation criteria.
We have completed a desk-based audit of our key suppliers’ statements to reassure ourselves they continue to operate in accordance with the requirements of the Act. We continue to ensure that we support staff in working with existing and new suppliers through training and understanding of our procurement practises and processes to prevent modern slavery and human trafficking. We fully understand our duty as a Trust as prescribed in legislation. Safeguarding colleagues also cover modern slavery within their CPD programme.
Key performance indicators
We monitor the effectiveness of our approach through:
the proportion of staff who have completed safeguarding training, including awareness of exploitation and trafficking
internal audit review of procurement compliance
the number of safeguarding referrals relating to exploitation
the number of whistleblowing concerns raised and addressed
completion of modern slavery due-diligence checks for identified key suppliers
Training
Every member of staff is trained on the policy (either in person or via e-learning) and is required to declare annually that they have read and understood the policy. In addition, E-ACT has a Whistleblowing Policy which enables those with concerns about any wrongdoing or breaches of law to raise these concerns in confidence, without fear of repercussion.
Throughout the year the annual safeguarding training plan across the Trust includes a detailed focus on early identification of those at risk of exploitation along with training to help all staff know what to do if they become aware of any potential risks. We are fully satisfied that, through our robust safeguarding training, staff could identify and act appropriately for at risk pupils, staff, and contractors.
This is not an area for complacency, and we keep our safeguarding policy and practice under closely scrutiny and evaluation. We continually enhance the knowledge of our staff to prevent slavery and human trafficking and child sexual exploitation. Safeguarding awareness sessions for modern slavery and trafficking at academy level are included within our staff safeguarding CPD plan.
We evaluate our processes for raising concerns, to ensure that there are clearly identified ways, available to all users of our estates, to report whistleblowing or modern slavery concerns.
Reporting
To date, no referrals have been made in relation to modern slavery.
Continuous improvement and priorities for 2024–2025
During the next reporting period we will:
further develop our risk-based supplier due-diligence process
enhance procurement training and guidance
review our KPIs to strengthen how we measure impact
This reflects our commitment to continuous improvement in preventing modern slavery and human trafficking.
Signed: Tom Campbell, Accounting Officer for E-ACT
Approved by the Board of Trustees: 26 March 2026
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