This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes MBIT Training Ltd’s (MBIT) slavery and human trafficking statement for the financial year ended 31 September 2019. This statement covers the activities of MBIT Training Ltd and its subsidiaries and trading names, which procure goods and services from and form part of MBIT’s supply chain.
MBIT is a leading IT technical corporate training provider. We operate a combination of corporate training for direct B2B customers, some B2C public training and consultancy through our website, but also subcontract training for larger, other established training providers where skill requirements are niche and no in-house staff member is able to provide the delivery.
We have around 10 freelancers who we outsource work to and work with, but no direct staff other than the Director who is salaried by the company. Our focus is to ensure there are policies and procedures in place for our contractors and suppliers as well as protections within our subcontractor projects when working with other competitors to ensure that needs are met.
MBIT is committed to continuously improving its practices to identify and eliminate any slavery and human trafficking in its business and supply chains, and to acting ethically and with integrity in all its business relationships.
MBIT uses a wide range of suppliers who supply goods for sale, provide services at events and support our operations.
Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015. As part of this process, we have undertaken a review of our supply chain to identify and assess potential risk areas and maintain a register detailing the same. We have identified that by outsourcing technical services globally, especially to third-world countries we run a risk of encountering slavery.
We expect high standards from all of our subcontractors, suppliers and other business partners and have made this a contractual term in our agreements with significant suppliers wherever possible
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
The management of the firm has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all of our people comply with it.
The legal department has primary and day-to-day responsibility for implementing this policy, but the procurement team provide assistance with reviewing the risk profile of our supply chain to ensure that any procedures implemented are effective in countering modern slavery.
COMPLIANCE WITH THE POLICY
As a member of staff, you must ensure that you read, understand and comply with this policy. For transparency, this document will feature publicly on our website.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Although you should report any concerns regarding modern slavery and/or human trafficking in any parts of our business or supply chains in accordance with our whistleblowing policy, you are also encouraged to discuss a specific matter (or our policy or relevant legislation) with any member of the company’s strategic staff, for legal advisement.
If you are in any doubt about whether a particular act or working conditions in any of our business relationships may contravene any aspect of this policy then err on the side of caution and report it as an act of whistleblowing, or with any member of the company’s strategic staff, for legal advisement.
We encourage openness and will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their knowledge, or suspicion, that modern slavery is taking place in any part of our business or in any of our supply chains.
Our zero-tolerance approach to modern slavery is communicated to all significant suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Any employee who breaches this policy could face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
We continue to monitor suppliers we believe present high modern slavery risks in our supply chain. This includes those who support the procurement of goods and materials for our fundraising and marketing activities, particularly where those goods and materials are acquired from suppliers in high risk countries.
All suppliers which we class as high risk must:
For manufacturing facilities in the supply chains of high risk suppliers we request that the operators of those facilities:
Our MBIT staff are responsible for assessing the information submitted by suppliers. Should a supplier fail to provide the information requested or to meet MBIT’s expectations, MBIT will take appropriate action, which may include not entering into a relationship or terminating the relationship with the supplier concerned.
During the year, we have continued to provide advice and guidance to those teams who have direct responsibility for relevant supply chains and our Procurement team has participated in further modern slavery training. We also maintain a Modern Slavery Act Guidance document which is available to staff through MBIT’s intranet.
Over the course of the next financial year we will continue to enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers.
This statement has been formally approved by the Director of MBIT Training Ltd and signed on their behalf.
Mr Matthew John Bennett
MBIT Training Ltd