Engage‌ Education Modern Slavery ‌Policy ‌2026/2027

• 1. Engage Education is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
• 2. Engage Education is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
• 3. This policy is written to meet our obligations under, and to align with current expectations set out in, the Modern Slavery Act 2015 (including our section 54 transparency obligations), the Procurement Act 2023, PPN 009 (Guidance on tackling modern slavery in government supply chains, which supersedes earlier guidance under PPN 05/19 and PPN 02/23), and requirements published by the Government Commercial Agency (GCA) — the Cabinet Office agency formed on 1 April 2026 from the merger of Crown Commercial Service (CCS) and the Cabinet Office’s Central Commercial Teams, which now sets government-wide commercial standards including modern slavery due diligence. We also have regard to guidance from the Recruitment and Employment Confederation (REC) and the Stronger Together initiative on tackling hidden labour exploitation in recruitment supply chains
• 4. We conduct due diligence on our suppliers and business partners to identify and mitigate risks of modern slavery. This includes requesting evidence of their modern slavery policies and statements where required by law, conducting risk assessments of our supply chains with particular focus on higher-risk sectors, countries and stages of the supply chain, including modern slavery clauses in our contracts with suppliers, conducting audits and assessments of suppliers where appropriate, reserving the right to audit suppliers where concerns arise, and working with suppliers to improve standards where issues are identified. As part of this due diligence, we ask suppliers to confirm that they have an equivalent graduated, action-plan-led process for responding to any modern slavery issue identified in their own supply chain, in line with clause 16.
• 5. Engage Education does not use recruitment agencies, labour providers, or sub-agents to source workers. All work-seekers we supply are identified, registered and engaged directly by Engage Education staff, without any intermediary. We consider this a structural safeguard against debt bondage and other risks associated with agency-charged fees and sub-agent recruitment chains, in addition to the specific steps set out in clause 6 below.
• 6. For workers we supply, we take the following steps to prevent modern slavery. We verify right to work in the UK for all workers and ensure workers are not charged recruitment fees. We conduct face-to-face or video interviews with all workers and ensure workers are paid directly into their own bank accounts. We ensure workers are paid at least the national minimum wage and provide information about workers’ rights and how to report concerns. We monitor working conditions and hours to identify any concerns.
• 7. We regularly assess the risk of modern slavery in our business and supply chains, using external resources such as the Global Slavery Index and industry guidance, engaging with workers, suppliers and external stakeholders to identify risks, and reviewing and updating our findings regularly. We have identified our highest-risk areas as follows:
  • Categories: our highest-risk category is the service we exist to provide — the supply of temporary workers. Within our own supply chain, we treat services purchased for operational use, particularly IT services, software development, and cleaning and facilities management, as a higher-risk category of goods and services not for resale.
  • Vulnerable groups: we recognise migrant and overseas workers as a higher-risk
    vulnerable group, reflecting the risks set out in clause 6, and apply enhanced due diligence to international recruitment accordingly. We also recognise women as a vulnerable group, given the composition of the education workforce we place, and remain alert to risks of unequal treatment, harassment or exploitation. As part of our registration process, we record candidates’ immigration status and, where relevant, refugee status, and treat candidates with refugee status or another form of precarious immigration status linked to their right to work as a heightened-risk group requiring enhanced verification and support. We place 16 and 17 year old apprentices in
    education settings, and treat these workers as a vulnerable group requiring additional safeguards: we apply enhanced supervision, safeguarding checks and monitoring in line with our Child Protection and Safeguarding Policy to every such placement, in addition to the checks in clause 6 that apply to all workers we supply.
  • Types of work: temporary and agency work — the nature of our core business — is a higher-risk type of work, given the vulnerabilities that temporary and short-term engagements can create for workers
  • Sectors: we have identified cleaning and facilities management services, and IT services and software development, as higher-risk sectors within our operational supply chain. We have identified professional services such as legal and accounting, UK-based recruitment advertising, and office supplies from established UK suppliers as lower-risk. We do not place workers into, or supply services within, the construction sector or other sectors outside education.

Where we are asked to identify the areas of highest modern slavery risk in our organisation and supply chains (for example under an MSAT or equivalent assessment), our response covers all four of the above: categories, vulnerable groups, types of work, and sectors.

• 8. In line with the Ethical Trading Initiative Base Code, the Employer Pays Principle, and the standards expected under MSAT and equivalent client assessments, Engage Education requires that, in respect of all workers we supply and all workers within our own business and supply chain:
  • All employment complies with local and national laws.
  • Workers are free to terminate their employment, giving reasonable notice, without penalty.
  • Workers have freedom of movement and are not restricted, confined, or prevented from leaving their accommodation or workplace outside of working hours.
  • Workers are free to join or form a trade union or other worker representative body of their
    choosing, and to bargain collectively, without fear of reprisal, intimidation or harassment. Where a worker we supply is represented by a trade union, we engage with that union as part of our HR, safeguarding and complaints processes on a case-by-case basis; we do not hold a formal partnership agreement with any specific education-sector union.
  • No worker is subject to, or threatened with, violence, harassment, intimidation, or any form of physical, verbal or psychological abuse.
  • No worker, or prospective worker, is charged recruitment fees or related costs, whether directly or indirectly, in connection with securing employment.
  • Overtime is voluntary, and no worker is subject to compulsory or excessive overtime.
  • No child labour is used at any stage of our business or supply chain, and we verify the age and right to work of every worker we supply. Where we place 16 or 17 year old apprentices in education settings under a lawful apprenticeship scheme, this is not treated as child labour, but is subject to the enhanced safeguards described in clause 7.
  • No worker is discriminated against on the grounds of race, gender, age, religion,
    disability, sexual orientation, marital status, or any other protected characteristic, in accordance with our Equal Opportunities Policy.
  • No worker’s original identification, immigration or travel documents (including passports, visas or right-to-work evidence) are confiscated, withheld or retained by us or by any supplier, agent, or employer in our supply chain.
  • Victims of modern slavery are provided with access to remedy, including support services,
    compensation for any loss suffered, and access to justice, in accordance with clause 16 below.

We will not knowingly do business with any supplier, agent, or organisation in our supply chain that fails to meet these standards, and will take the action set out in clauses 15 and 16 where a breach is
identified.

• 9. We recognise that irresponsible purchasing practices — by us as a buyer, or by our clients as buyers of our services — can create or increase the risk of modern slavery in a supply chain, even where a supplier’s own policies appear sound. In line with PPN 08/21 and Stronger Together guidance on responsible purchasing, we are committed to:
  • Pricing our services, and expecting to be paid by our clients, at a level that reflects the true cost of responsible employment, and not seeking or accepting pricing so aggressive that it cannot sustain lawful pay and conditions for the workers we supply.
  • Giving our suppliers and workers realistic lead times for assignments and requests, and, in our role as a supplier, asking our clients to do the same for us.
  • Avoiding, and asking our clients to avoid, late requests for high volumes of workers at short notice that cannot reasonably be resourced without cutting corners on worker checks.
  • Forecasting our own workforce and placement requirements as accurately as possible, and working with clients to improve the accuracy of the demand information they give us, so that resourcing decisions are not driven by poor planning.
  • Paying our suppliers and workers on time and in full, in line with our contractual terms, and expecting the same prompt payment from our clients.
  • Not withdrawing from contracts, assignments or bookings at the last minute other than for good reason, and giving suppliers, workers and clients reasonable notice of any change.
  • Not applying, and not accepting from clients, unfair penalties or charges where a worker or supplier is unable to meet an order or assignment because of a late change that was outside their control.
  • Providing accurate and complete technical, role and placement specifications, so that suppliers and workers are not required to work outside agreed terms or take on additional risk to meet a poorly specified requirement.

Our Financial Director and Associate Director of Compliance will review our own purchasing and
contracting practices against these commitments as part of the annual review referred to in clause 11, and will raise any concerns about a client’s purchasing practices where these are placing workers at risk.

• 10. We consider the risk of modern slavery at every stage of the procurement and contracting lifecycle, whether we are the buyer engaging a supplier or subcontractor, or the supplier responding to a client’s process. Specifically:
  • Needs identification: when a requirement for workers or services first arises, we consider
    whether the sector, role, location or workforce type carries an elevated modern slavery risk (see clause 7) before deciding how to proceed.
  • Requirement definition: when defining the requirement, we build in modern slavery safeguards from the outset, including accurate role and technical specifications, realistic timescales, and clear right-to-work and pay requirements (see clauses 8 and 9).
  • Tender evaluation, including scoring and adjudication: where we select suppliers or
    subcontractors, we take account of their modern slavery policies, statements and due diligence evidence as part of our evaluation, and we expect clients evaluating us to do the same (see clause 4).
  • Contract award: our contracts and terms of business with suppliers include modern slavery clauses requiring compliance with the Modern Slavery Act 2015, our Code of Conduct, and a right for us to audit compliance.
  • In-life contract management: we monitor compliance throughout the life of a contract or
    assignment through spot checks, worker interviews, MSAT campaigns where relevant, and
    ongoing review of the risk indicators set out in this policy.
  • End of contract review: at the end of a contract, assignment or relationship, we review the
    supplier’s or subcontractor’s modern slavery compliance record, capture any lessons learned, and use this to inform future needs identification and supplier selection.
• 11. We maintain our readiness to respond to MSAT and equivalent client assessments by keeping this policy, our modern slavery statement, and related policies (Code of Conduct, Whistleblowing, Anti-Bribery and Safeguarding) up to date and mapped against the themes such assessments typically cover — governance, policies, risk assessment, due diligence, training and remediation. Our Associate Director of Compliance and Financial Director are responsible for keeping supporting evidence (right-to-work checks, payment records, worker interviews, supplier due diligence) readily available, for reviewing and re-submitting MSAT responses at least annually or whenever a client’s campaign requires it, and for tracking any risk flags or recommendations raised by a completed assessment through to resolution within an agreed timeframe. We monitor GCA and Home Office publications so that this policy and our MSAT responses remain current, and this policy will be updated if a materially revised MSAT question set or scoring methodology is published.

As a Corporate Member of the Recruitment and Employment Confederation (REC), we undergo an
external audit against the REC Code of Professional Practice every 2 years, including checks on our pay records against the national minimum wage and on our right-to-work compliance. We treat the outcome of this audit as further external evidence supporting our MSAT responses and this policy, and will make it available to clients or assessors on request.

In addition to this external audit, we carry out weekly internal audits of payroll and maintain internal control measures to ensure ongoing adherence to the national minimum wage and to our right-to-work checks throughout the hiring process, from initial registration through to each individual placement. We also carry out termly surveys of candidates to assess worker satisfaction and identify any concerns about their treatment or working conditions. Survey results are reviewed by our Associate Director of Compliance, and any concerns raised are followed up in line with clauses 13 to 16 of this policy.

• 12. Engage Education provides appropriate training and awareness information for all of its staff. In particular:
  • Our Senior Leadership Team receives detailed training in identifying and resolving concerns around modern slavery and human trafficking.
  • Our staff involved in our procurement and supply chains undertake training courses that
    include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
  • All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking so that they can bring any concerns they have to the attention of management.
• 13. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to our Financial Director, Bejal Bhudia or our Associate Director of Compliance, Joseph Raffell.
• 14. Staff, workers and other parties can also report concerns externally to the Modern Slavery Helpline on 0800 0121 700, which operates 24 hours a day, 7 days a week and is confidential, the Police on 999 for emergencies or 101 for non-emergencies; the Gangmasters and Labour Abuse Authority on 0800 432 0804; or Crimestoppers on 0800 555 111, which is anonymous. The Modern Slavery Helpline and Crimestoppers both offer support in multiple languages. Where a migrant worker wishes to raise a concern with us directly but is not confident doing so in English, we will arrange interpretation or translation support at no cost to the worker, and will provide any update or feedback on their concern in a language they understand.
• 15. Reports surrounding these issues are taken extremely seriously by our Board of Directors, who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
  • Working with the appropriate organisations to improve standards,
  • Removing that organisation from our preferred supplier list,
  • Passing details to the appropriate law enforcement bodies.

Service Level Agreement for responding to reports: we will acknowledge receipt of any report within 1 working day; complete an initial triage, assessing urgency and any immediate safeguarding risk, within 2 working days; apply any necessary victim safety measures immediately, regardless of how long the wider investigation takes; conclude a standard investigation within 10 working days of the initial triage, or provide the reporter with a revised timeframe and reason for any extension; and, where the report was not made anonymously, communicate the outcome and any action taken to the reporter within 5 working days of the investigation concluding. Urgent reports involving an immediate risk to a worker’s safety are fast-tracked and are not subject to these standard timeframes.

In addition to investigating individual reports, our Board of Directors will review the effectiveness of our whistleblowing and grievance mechanisms at least annually, including reporting channel usage, worker awareness of how to raise a concern, and whether any barriers to reporting — such as language, accessibility, or fear of reprisal — have been identified, and will approve any resulting improvements.

• 16. Where modern slavery is identified, we are committed to taking immediate action to protect victims, working with appropriate authorities and organisations, providing or facilitating access to remedy for victims, and reviewing our processes to prevent recurrence. In particular:
  • We do not automatically de-list or terminate trade with a supplier where an issue is identified, including where the supplier is found not to be complicit. Termination is a last resort, applied only where a supplier is unwilling or unable to remediate.
  • Any supplier where a gap, breach, or suspected incident has been identified is required to
    provide us with a formal corrective action plan, addressing: the specific gaps or deficiencies identified in their policies or processes; the root cause of the incident; the corrective action they will take, and by whom; and a realistic timeframe for delivery.
  • We expect our suppliers to apply this same graduated, action-plan-led approach to their
    own subcontractors, and, as part of the due diligence set out in clause 4, ask suppliers to confirm they have an equivalent process in place.
  • We will terminate a supplier relationship where the supplier is unwilling or unable to deliver an agreed corrective action plan, or fails to remediate within the agreed timeframe.
• 17. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:
  • The effectiveness of enforcement against suppliers who breach policies,
  • The amount of time spent on audits, re-audits, spot checks, and related due diligence, and
  • The level of modern slavery training and awareness amongst our staff,
  • The percentage of staff who have completed modern slavery training,
  • The percentage of workers who have had right to work verified,
  • The number of modern slavery concerns reported and investigated,
  • The speed of investigation from report to conclusion,
  • The number of suppliers assessed for modern slavery risks, and
  • Scores and risk flags arising from MSAT or equivalent client assessments, and the time taken to resolve any resulting action points, and
  • Completion of the annual senior-leadership review of the effectiveness of our whistleblowing and grievance mechanisms referred to in clause 15, and the number of improvements made as a result, and
  • Completion rates for our termly candidate satisfaction surveys referred to in clause 11, and the number and nature of any concerns raised through them.
• 18. As part of our efforts in this area, we publish a modern slavery statement on an annual basis.
• 19. We would also recommend reading this in conjunction with our other policies, including our:
  • Social value policy
  • Anti-bribery policy
  • Whistle-blowing policy
  • Modern slavery statement (04/2026)
  • Current guidance published by the GCA and the Home Office, including PPN 009

This policy, our Modern Slavery Statement, and the other policies listed above are published on our
website at www.engage-education.com, and are available to all workers, including our own internal
staff, the temporary workers we supply, and workers within our operational supply chain. This policy is provided to all internal staff as part of their induction, and communicated to them alongside the training referred to in clause 12. We communicate the existence and location of these policies to the workers we supply at the point of registration, and to our operational suppliers as part of the due diligence and contracting process described in clause 4.

This policy was adopted on 01/04/2026 after being agreed upon by our Board of Directors. Updates were made in June 2026 and July 2026 to ensure adherence to required legislation. Updates have been checked and approved by the board. It is reviewed annually and will next be formally reviewed no later than April 2027, or sooner if there is a material change to our business, our supply chain, or the legal and regulatory framework described in clause 3.

Signed:

Joseph Jones Raffell – Associate Director – Compliance
Dated 30/07/2026