Modern Slavery & Human Trafficking Policy
1.Policy Statement
SanctuaryGraduates is committed to conducting business ethically, responsibly and withrespect for human rights. We have a zero-tolerance approach to modern slavery,human trafficking, forced labour, servitude, debt bondage, child labour and anyform of exploitation within our own operations or supply chain.
This policysupports our commitment to fair work, responsible recruitment, social mobility,diversity and inclusion. It is particularly relevant to the early careersmarket, where candidates must be treated fairly, transparently and withoutimproper fees, coercion or exploitation.
2. Scope
This policyapplies to all Sanctuary Graduates employees, workers, contractors,consultants, suppliers, delivery partners and any third parties acting on ourbehalf.
3. Legaland Regulatory Context
The ModernSlavery Act 2015 requires certain commercial organisations carrying on businessin the UK to prepare an annual slavery and human trafficking statement wherethe statutory criteria are met. Irrespective of reporting thresholds, SanctuaryGraduates is committed to maintaining proportionate controls to reduce the riskof modern slavery in its business and supply chain.
4. Our Business and Supply Chain Risk Profile
SanctuaryGraduates provides early careers recruitment, attraction, assessment, screeningand related services. Our supply chain is principally UK-based and service-led,including technology platforms, professional services, event venues, marketingsuppliers, assessment partners and contractors. The inherent risk of modernslavery in our direct operations is considered low; however, we recognise thatrisks can exist in any supply chain and must be actively managed.
Areas ofpotential risk include:
· Use of temporary, contractor orfreelance labour.
· Event venues, hospitality,cleaning, facilities or logistics suppliers.
· Technology, marketing oroutsourced service providers with extended supply chains.
· Any supplier operating inhigher-risk sectors or jurisdictions.
· Any recruitment activity wherecandidates could be charged improper fees or placed under pressure.
5.Principles and Commitments
· We do not knowingly work withany organisation involved in modern slavery or human trafficking.
· We expect suppliers andpartners to comply with all applicable labour, employment, immigration andhuman rights laws.
· We do not charge candidatesfees for recruitment services.
· We expect workers in our supplychain to be engaged freely, paid lawfully and treated fairly.
· We require concerns to beescalated promptly and investigated appropriately.
· We will take proportionateaction where a supplier fails to meet our standards, which may includeremediation, suspension or termination.
6.Supplier Due Diligence
SanctuaryGraduates will apply proportionate supplier due diligence based on the natureand risk profile of the supplier or partner. This may include:
· Assessing supplier location,sector, service type and labour model.
· Requesting confirmation ofcompliance with modern slavery, labour and employment laws.
· Reviewing relevant policies,statements or contractual commitments where appropriate.
· Including contractualobligations requiring lawful, ethical and responsible working practices.
· Escalating higher-risksuppliers for senior review before engagement.
· Monitoring supplier performanceand addressing concerns promptly.
7.Recruitment and Candidate Protection
As an earlycareers recruitment specialist, Sanctuary Graduates is committed to protectingcandidates from unfair, misleading or exploitative practices. We will:
· Provide candidates with clearinformation about roles, processes and expectations.
· Avoid misleading jobadvertising or inappropriate pressure on candidates.
· Ensure candidates are notcharged recruitment fees by Sanctuary Graduates.
· Support reasonable adjustmentsand fair access to selection processes.
· Maintain transparent candidatecommunication and escalation routes.
· Act promptly on any concernrelating to coercion, exploitation, improper fees or unsafe working conditions.
8.Training and Awareness
Relevant staffwill receive proportionate awareness of modern slavery risks, including warningsigns, escalation routes, supplier risk considerations and the importance offair recruitment practices. Training may be included within induction, annualrefreshers or project-specific briefings for higher-risk activity.
9.Reporting Concerns
Anyone workingfor or with Sanctuary Graduates must report any concern or suspicion relatingto modern slavery, human trafficking, forced labour or exploitation. Concernsshould be raised with a line manager, the Senior Leadership Team or through therelevant safeguarding, whistleblowing or escalation route. Concerns will betreated seriously, handled sensitively and investigated appropriately.
10.Response to Incidents or Concerns
Where a concernis identified, Sanctuary Graduates will assess the risk, protect any affectedperson where appropriate, preserve relevant information, engage specialistadvice where necessary, notify relevant authorities or clients where requiredand agree corrective action. The priority will be the safety and welfare ofaffected individuals, alongside lawful and ethical resolution.
11.Governance and Review
The SeniorLeadership Team is responsible for oversight of this policy. The policy will bereviewed annually, or sooner following a material change in law, businessoperations, supplier profile, client requirements or an identified incident.
12.Summary
SanctuaryGraduates has a zero-tolerance approach to modern slavery and humantrafficking. Our business is UK-based and service-led, with a low-riskoperating profile, but we recognise that modern slavery risk can exist in anysupply chain. We apply proportionate supplier due diligence, maintain fairrecruitment practices, do not charge candidates recruitment fees, train staffto recognise and escalate concerns, and will take appropriate action where anysupplier or partner fails to meet our standards.
