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, volunteers, agents, contractors and suppliers.

Entelechy Academy Limited strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

Policy statement

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Modern slavery and human trafficking

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.

The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

Consistent with our risk-based approach we may require:

employment and recruitment agencies and other third parties supplying workers to our organisation to

confirm their compliance with our Code of Conduct

Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code:

As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.

If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Commitments

For customers, contractors and suppliers working with Entelechy Academy Limited.

This Modern Slavery Code of Conduct (the “Code”) applies to Entelechy Academy Limited’s customers, contractors and suppliers. It sets out the minimum standards that we expect from these entities.

We are committed to the protection of human rights and to fair and ethical work practices. We understand that we have a responsibility to conduct our business ethically and this extends to our customers, contractors and suppliers.

We expect our customers, contractors and suppliers to share our commitment to respecting the rights of all workers and to act lawfully and ethically in all areas of business.

Not only do we ensure that modern slavery is not taking place within our own organisation, we also work to ensure it is not occurring within our supply chains.

It is a condition of all customer, supply and vendor contracts entered into with Entelechy Academy Limited that the principles set out in this Code are adhered to.

Background

This Code establishes minimum standards that we expect customers, contractors and suppliers to meet or exceed.

These standards do not intend to deviate from national or local laws or standards.

Failure to meet these standards may be cause for termination of any agreement entered into with Entelechy Academy Limited.

Minimum standards

We are opposed to the use of any form of child labour or practices. Our customers, contractors and suppliers must not use child labour.

Customers, contractors and suppliers are required to comply with applicable child labour laws and employ only workers who meet the applicable minimum legal age requirement in their countries of operation.

the minimum working age is 15 years (or 14 if allowed by national or local law)

workers under the age of 18 years are not to be involved in any work that is hazardous or likely to have a negative impact on the employee’s physical or mental development.

Customers, contractors and suppliers are to ensure the above protection for workers under the age of 18 years.

Customers, contractors and suppliers must not contract with subcontractors or suppliers who use or engage in child labour.

Child labour

Entelechy Academy Limited’s customers, contractors and suppliers must not participate, engage or promote forced, bonded, indentured or involuntary prison labour of people in any part of its business.

Trustpilot’s customers, contractors and suppliers must not participate, engage or promote the trafficking of any person.

All slavery and human trafficking laws must be complied with. Customers, contractors and suppliers must ensure they have taken steps to ensure their business operations are free from slavery and human trafficking practices, both internally and within their supply chains and other external business relationships.

Customers, contractors and suppliers are to ensure that all workers employed by them choose their employment freely and are not mentally or physically coerced to provide their labour.

Customers, contractors and suppliers must not contract with subcontractors or suppliers using or engaging in modern slavery or trafficking.

Forced or involuntary labour & trafficking

Customers, contractors and suppliers shall take all reasonable steps to ensure that modern slavery and human trafficking are not taking place within their supply chain or within any part of their business. Customers, contractors and suppliers must adhere to this Code along with all applicable national and local laws.

Customers, contractors and suppliers must be able to certify that materials included in their products comply with all requisite slavery and human trafficking laws. Entelechy Academy Limited may at any time request a supplier or contractor to supply a report setting out the steps they have taken to ensure that modern slavery and human trafficking is not taking place within their business or within their supply chain.

Customers, contractors and suppliers have a duty to immediately report to Entelechy Academy Limited any breach of or deviation from this Code by email to 

If a customer, contractor or supplier breaches this Code, we reserve the right to request from the supplier or contractor a corrective action plan. This plan is to set out the steps that the supplier or contractor will undertake to rectify the breach. Should the corrective action plan not rectify the breach and depending on the severity of the breach, we reserve the right to terminate any contractual relationship that exists.

Modern Slavery and Human Trafficking Policy

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