- 0208 381 1813
- info@mycccollege.com
- Mon - Sat: 8:00AM - 5:30PM
Last updated: June 2026
Policy owner: Senior Management
Approved by: Director
Version: 1.0
Effective date: 10 June 2026
Review date: 10 June 2027
Application: Staff, tutors, contractors, suppliers, subcontractors, delivery partners and all organisations working for or on behalf of London Cactus College.
London Cactus College is committed to preventing modern slavery, human trafficking, forced or compulsory labour, servitude and exploitation in all areas of its work. The College has zero tolerance for any form of modern slavery and expects the same standard from everyone who works for us, with us or on our behalf.
This policy supports the College’s commitment to safeguarding, equality, ethical employment, responsible procurement and compliance with the Modern Slavery Act 2015. It is intended to provide clear assurance for tender applications, contract delivery and ongoing supplier management.
The College recognises that modern slavery can occur in many settings, including education, cleaning, facilities, recruitment, transport, hospitality, accommodation, agency labour and subcontracted services. We therefore take reasonable and proportionate steps to identify, prevent, reduce and respond to modern slavery risks within our organisation and supply chains.
The purpose of this policy is to set out how London Cactus College prevents and responds to modern slavery risks and how responsibilities are allocated across the organisation. It also explains the standards expected of suppliers and partners when delivering services connected to the College.
This policy applies to all employees, senior managers, tutors, assessors, agency workers, temporary workers, volunteers, contractors, consultants, suppliers, subcontractors, delivery partners and any other organisation or individual acting for or on behalf of London Cactus College.
The College expects all relevant parties to act consistently with this policy and to comply with applicable employment, safeguarding, equality, health and safety, immigration, procurement and anti-slavery requirements.
The Modern Slavery Act 2015 defines offences relating to slavery, servitude, forced or compulsory labour and human trafficking. Government guidance on transparency in supply chains explains that relevant organisations should set out the steps they take to prevent modern slavery in their business and supply chains, including policies, due diligence, risk assessment, training and effectiveness measures.
Although statutory reporting obligations depend on organisational size and turnover, London Cactus College is committed to applying proportionate modern slavery controls and maintaining evidence suitable for tender submissions and contract monitoring.
For the purposes of this policy, modern slavery includes slavery, servitude, forced or compulsory labour, human trafficking, debt bondage, labour exploitation, criminal exploitation and any situation where a person is controlled, coerced, deceived or abused for the purpose of exploitation.
Potential indicators may include a person appearing fearful or withdrawn, being unable to explain their working arrangements, having limited control over identification documents or wages, being accompanied or controlled by another person, working excessive hours, living in unsuitable accommodation, or being prevented from raising concerns freely.
Â
The Director and Senior Management are responsible for ensuring that the College has appropriate arrangements to prevent, identify and respond to modern slavery risks. They will provide leadership, approve this policy, allocate responsibilities, review significant concerns and ensure corrective action is taken where required.
Managers and relevant staff must understand this policy, remain alert to signs of exploitation, follow safeguarding and HR procedures, apply appropriate procurement checks, report concerns promptly and cooperate with any investigation or review.
All individuals covered by this policy must read, understand and comply with it. They must avoid any activity that could lead to or suggest a breach of this policy and must raise concerns at the earliest possible opportunity.
London Cactus College is committed to fair, lawful and ethical employment practices. The College will seek to ensure that staff and workers are recruited through appropriate processes, have clear terms of engagement, are paid in accordance with legal requirements and are not subject to coercion, deception, intimidation or unlawful deductions.
The College will apply appropriate right-to-work checks, identity checks, safeguarding arrangements and HR controls in line with relevant legal and regulatory requirements. Where agency or subcontracted labour is used, the College will expect the supplying organisation to demonstrate that equivalent employment and welfare controls are in place.
The College recognises that modern slavery risks may arise through suppliers, subcontractors and service partners. Procurement decisions will therefore take account of ethical standards, labour practices, safeguarding requirements and the nature of the goods or services being supplied.
The College will assess modern slavery risks proportionately, considering the type of service, use of agency or lower-paid labour, subcontracting, geographic location, sector risk, contract value and any previous concerns. Risk assessment will be used to decide the level of due diligence, contract controls, monitoring and escalation required.
Where concerns or higher-risk indicators are identified, the College will consider appropriate action, which may include seeking further information, requiring a supplier improvement plan, increasing monitoring, escalating to senior management, referring safeguarding concerns, or ending the relationship where necessary and lawful.
Any person who believes or suspects that modern slavery, exploitation or human trafficking has occurred, is occurring or may occur must report the concern promptly. Concerns should be reported to the Safeguarding Designated Person, Cindy Teo, at cteo@mycccollege.org, or to a member of Senior Management if the concern relates to the usual reporting route.
Concerns may also be raised through the College’s safeguarding or whistleblowing arrangements where appropriate. Reports will be treated sensitively, shared only with those who need to know and managed with the welfare and safety of any affected person as the priority.
London Cactus College will respond to concerns promptly and proportionately. The College will record reported concerns, assess immediate safeguarding or welfare risks, preserve relevant information, escalate to senior management where appropriate and cooperate with statutory agencies if required.
Where a supplier or partner is involved, the College will seek to address concerns in a way that prioritises the welfare of affected individuals and avoids actions that could increase harm. Corrective action may include an improvement plan, enhanced monitoring, suspension of work, referral to relevant authorities or termination of the contract where appropriate.
The College will promote awareness of modern slavery risks through induction, safeguarding communication, procurement processes and management oversight. Staff involved in recruitment, safeguarding, procurement, contract management or supplier engagement should understand the signs of exploitation, reporting routes and the importance of acting promptly.
The College will keep appropriate records of reported concerns, supplier checks, risk assessments, training activity and actions taken in response to identified risks. Senior Management will review this policy at least annually, or sooner if legislation, guidance, tender requirements or organisational arrangements change.
For tender applications and contract delivery, London Cactus College will provide evidence of this policy and, where requested, supporting information about safeguarding arrangements, recruitment controls, supplier due diligence, reporting routes, training and governance. The College will cooperate with reasonable audit, monitoring and assurance requirements connected to modern slavery prevention.