Tribal Group Plc Slavery and Human Trafficking Statement
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 by s.54 of the Modern Slavery Act 2015 (Act).
This is Tribal Group plc’s (Tribal) slavery and human trafficking statement for the last financial year ended December 31 2016 and current as at 30 June 2017.
The purpose of the Act is to eradicate modern slavery, which encompasses human trafficking, slavery, forced labour and servitude. The Act has the effect of exposing companies to the common practices of contract governance through the transparency the Act imposes on its supply chains, policies and procedures. The Act 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.
Our Business and Organisational Structure
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. There is an element of seasonality by our clients in using our services, usually around times of enrolment, assessment and reporting obligations.
Tribal’s group structure is detailed in the Corporate Entities Table below which includes its overseas subsidiaries and branches. The Group’s turnover is in excess of £90 million per annum (2016 Annual Report and Accounts).
Our Supply Chains and their adherence to our values
As a global business, Tribal has a number of clients, sub-contractors, associates and employees who are based inside and outside the UK. Tribal recognises the need to ensure its compliance with the provisions of the Act beyond the UK and has therefore introduced changes across the entire business to ensure compliance with the Act.
A substantial portion of Tribal’s clients are government and educational organisations that also need to comply with requirements of the Act.
In the main, Tribal’s supply chain is based in low risk countries where modern forms of slavery are not prevalent. Tribal’s supply chains consistent mainly of human resources to perform skilled services, whether they be employees, sub-contractors, associates or agents. Traditionally, Tribal has excellent relationships with trade unions and representative bodies that represent the interests of our workforce.
Tribal also sources software from third parties to facilitate the production of its own services or incorporated into its products.
Tribal’s business model is substantially the development, licence, implementation, hosting and support of its own software products. It also conducts quality assurance audits of educational institutions, undertakes survey and research of educational institutions and produces benchmark reports based on its industry knowledge and expertise.
Tribal is often required to negotiate and enter into contractual arrangements dictated by its customer’s standards and contracts, usually as part of a tender process.
During the last financial year Tribal’s processes have been tightened in relation to review, negotiation and approval of contracts proposed to be entered into by Tribal. In particular, Tribal has redrafted its Delegation of Authority Policy (DOA Policy). Relevantly, the DOA Policy requires all contracts to be reviewed, negotiated and signed off by the Global Legal Team and the Global Finance Team. This ensures that all contracts are reviewed for compliance with all Tribal governance policies, including its Antislavery Policy.
Our Policies and Due Diligence Process for Slavery and Human Trafficking
Tribal is committed to ensuring that there is no human trafficking and slavery taking place in our company and supply chains. Tribal’s Antislavery Policy supports its commitment to acting ethically and with integrity in all its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in its supply chains, globally.
Tribal has a number of mitigating policies/procedures/practices to manage the inherent risks, including:
• Only using licenced premises to optimise the control over the environment;
• Considering the geographical location of suppliers and the risks particular to that location;
• Establishing long standing relationships with customers and suppliers;
• Requiring each entity in the chain to apply their due diligence on the next link in the chain as it is not always possible/practical for Tribal to have a direct relationship with all links in the chain; and
• Effective systems to encourage the reporting of concerns and the protection of whistle blowers – during the last financial year the Whistleblowing Policy was reviewed and re-written to ensure it was, amongst other issues, appropriate to manage a report under the Act.
• A Global Governance Team which oversees and manages the governance obligations of Tribal, including compliance with the Act.
Risk and Mitigation
Tribal recognise that in order to manage its compliance with the Act, especially throughout its non-UK operations, that it is essential to have and 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 this and all governance policies is the fundamental foundation necessary to influence positive and appropriate behaviour within the organisation. This approach also influences suppliers and subcontractors particularly when risk assessment of their operations is undertaken comprehensively.
In furtherance of this philosophy, during the financial year, Tribal established a Global Governance Team which reports to the board of directors on a monthly basis in relation to the global governance policies, processes and issues. This includes compliance with the Act.
Our effectiveness in combating Slavery and Human Trafficking
The Global Governance Team uses a few key performance indicators to measure Tribal’s effectiveness in tackling slavery and human trafficking within the business and its supply chain:
• Measuring minimum labour standards required of Tribal, its subsidiaries and suppliers, globally and how these align to industry standards;
• Whether, when contracting with a new supplier or customer or renewing a contract with an existing customer, sufficient and appropriate information regarding compliance with the Act has been provided; and
• The measures to be taken if suspicious activity has been identified in Tribal’s supply chain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the current financial year. It has been reviewed and approved by the board of directors.
Director and Company Secretary
Tribal Group plc