This statement is made as part of Engage Education’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Engage Education operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.

This statement is published in accordance with section 54 of the Act and relates to the financial year April 2026 to April 2027. Please note that updates were made to this document in July 2026; these updates received board approval.

Introduction

This statement constitutes Engage Education Groups’ modern slavery and human trafficking transparency statement as of April 2026. The statement sets down Engage Education’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns, and management is expected to act upon them.

This statement should be read alongside our Modern Slavery Policy 2026/2027, which sets out the
standing rules, responsibilities and controls referred to throughout this statement.

1 Our Business

Engage Education is a limited company operating in the recruitment sector. We provide introduction
services and supply temporary workers in the education sector. Engage Education is an independent
business. As part of our structure, our supply chain includes technology providers, compliance and
auditing partners, payroll and finance software providers, training organisations and other third-party
service providers who support the operation of our recruitment business. These suppliers are primarily based in the UK and provide services that support our internal operations rather than the delivery of temporary workers.

We do 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.

1.1 Who we work with

All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. Our staff identifies all of the temporary workers we supply. We do not supply work-seekers to hiring companies through any intermediaries.

The hiring companies that we work with are located in the UK. The workers we supply live in the UK,
Ireland, Canada, Australia, South Africa, and the UAE.

In addition to hirers and work seekers, we engage a range of operational suppliers such as IT systems
providers, marketing partners and professional service firms. All suppliers are subject to our due diligence processes.

We recruit workers from overseas who live in the UK, Ireland, Canada, Australia, South Africa and the
UAE, which we recognise as a higher-risk area for modern slavery. We take specific steps in relation to international recruitment to mitigate these risks. We verify the right to work in the UK for all workers and ensure workers are not charged recruitment fees. We provide clear information about terms and conditions before workers travel and ensure workers have appropriate accommodation arranged where we arrange this. We conduct enhanced checks on any overseas recruitment partners and provide information about workers’ rights in their own language where possible.

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 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.

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 that apply to all workers we supply. This is not treated as child labour, which we prohibit at every stage of our business and supply chain.

1.2 Other relationships

As part of our business, we also work with the following organisations:
● The Department for Education
● The Government Commercial Agency (GCA), formerly the Crown Commercial Service
● The Recruitment and Employment Confederation (www.rec.uk.com)
● The Fair Work Agency (FWA) and its predecessor, The Employment Agency Standards
Inspectorate (EAS)
● The Stronger Together initiative, on tackling hidden labour exploitation in recruitment supply
chains

2 Our Policies

Engage Education has a Modern Slavery Policy 2026/2027 that is available to view on our website, and is provided to all internal staff as part of their induction. Our Modern Slavery Policy has been reviewed to reflect current public sector procurement requirements, including PPN 009 (Tackling Modern Slavery in Government Supply Chains), the Procurement Act 2023, and the Government Commercial Agency (GCA).

In addition, Engage Education has the following policies, which incorporate ethical standards for our staff and our suppliers.

• To view a list of our data processing policies, please visit the Privacy page on our website:
  https://engage-education.com/policies
• Corporate Social Responsibility Policy 2026 – viewable on our website
• Code of Conduct Policy 2026 – viewable on our website
• Anti-Bribery Policy 2026 – viewable on our website
• Whistleblowing Policy 2026 – viewable on our website
• Engage Education Child Protection & Safeguarding Policy 2026 – viewable on our website
• Equal Opportunities Policy 2026 – viewable on our website

2.1 Policy development and review

Engage Education’s policies are established by our senior leadership team, which includes our CEO,
Associate Director of Education & Safeguarding and Head of Marketing, based on advice from HR
professionals, industry best practice and legal advice, and in consultation with our Head of HR, HR
advisory consultants and the REC. We review our policies regularly, or as needed, to adapt to changes, and no later than annually.

3 Our Processes for Managing Risk

To assess the risk of modern slavery, we use the following processes with our suppliers:
When engaging with suppliers, we ask for evidence of their processes and policies, including
commitments around modern slavery, human trafficking, forced labour, human rights, and
whistle-blowing. 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 (see Section 7).

Although we have not identified any high risk activities, we recognise that certain aspects of our
operations carry an inherent level of risk, including the recruitment of international candidates, the use of temporary labour and reliance on external service providers. We therefore continue to assess these areas regularly and remain alert to any changes that may increase vulnerability to exploitation.

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.
• Vulnerable groups: migrants and overseas workers, women, candidates with refugee status or
  precarious immigration status, and the 16 and 17 year old apprentices we place, as set out in
  Section 1.1.
• Types of work: temporary and agency work, the nature of our core business, given the
  vulnerabilities that temporary and short-term engagements can create for workers.
• Sectors: cleaning and facilities management services, and IT services and software development, within our operational supply chain. We do not place workers into, or supply services within, the construction sector or other sectors outside education.

We have identified the following as lower-risk areas: professional services such as legal and accounting, UK-based recruitment advertising, and office supplies from established UK suppliers.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems, and review this risk assessment at least annually, or sooner if our business, our supply chain, or the regulatory environment changes materially.

Responsibility for the Company’s anti-slavery initiatives is as follows:

• Policies: The Head of People is responsible for creating and reviewing policies annually, looking at industry best practice and implementing any relevant amendments.
• Risk assessments: The Office Manager is responsible for risk assessments in respect of human
  rights and modern slavery, by reviewing our business activities, confirming the right to work of all candidates, and confirming that rates of pay are in accordance with local legislation.
• Due Diligence: The Finance Director is responsible for due diligence in relation to known or
  suspected instances of modern slavery and human trafficking, including reviewing suppliers’
  financial history, the governing or regulatory body they belong to, and customer references where material.
• MSAT and client assessments: Our Associate Director of Compliance and Financial Director are
  responsible for keeping supporting evidence readily available, for reviewing and re-submitting
  responses to the Modern Slavery Assessment Tool (MSAT) or equivalent client assessments at
  least annually or whenever requested, and for tracking any risk flags through to resolution.

Additionally, we have taken the following steps to minimise the possibility of any problems:

• We reserve the right to conduct spot checks of the businesses that supply us, in order to
  investigate any complaints.
• We require the businesses we work with to publish a modern slavery statement.
• We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
• Only senior members of staff who have undergone appropriate training for assessing modern
  slavery risks in the supply chain are authorised to sign contracts and establish commercial
  relationships in any area where we have identified the risk potential.
• Our staff are encouraged to bring any concerns they have to the attention of management.

3.1 Due Diligence for Workers We Supply

For workers we supply, we verify right to work in the UK, ensure workers have bank accounts in their own name and not third-party accounts, check workers are paid directly and not through intermediaries, verify workers’ addresses and living arrangements where concerns arise, conduct face-to-face or video interviews with all workers, and provide information about workers’ rights and how to report concerns.

We train our staff to recognise potential indicators of modern slavery. In workers we supply, these indicators may include signs of physical or psychological abuse, appearing malnourished, unkempt or inadequately clothed, showing signs of having been denied access to medical care, appearing to be under the control of others and rarely acting or speaking for themselves, not being in possession of their own passport or identity documents, having limited or no access to their earnings, working excessive hours over long periods, having limited or no social interaction, being unable to move freely, being threatened with being handed over to authorities, fear of law enforcement, or exhibiting signs of trauma such as anxiety, fear or depression.

In our supply chain, indicators may include unusually low prices that don’t reflect labour costs, reluctance to provide information about workers or supply chains, evidence of workers being charged recruitment fees, workers being paid below minimum wage, workers not having written contracts, evidence of workers living in overcrowded or substandard accommodation, or a lack of appropriate health and safety measures.

3.2 Responsible Purchasing Practices

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 at a level that reflects the true cost of responsible employment; giving our suppliers and workers realistic lead times, and asking our clients to do the same for us; avoiding late requests for high volumes of workers at short notice that cannot be resourced without cutting corners on worker checks; forecasting our own workforce requirements as accurately as possible; paying our suppliers and workers on time and in full, 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; not applying unfair penalties where a worker or supplier cannot meet an order due to a late change outside their control; and providing accurate and complete technical, role and placement specifications.

3.3 Modern Slavery Risk Throughout the Procurement Lifecycle

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: needs identification, requirement definition, tender evaluation (including scoring and
adjudication), contract award, in-life contract management, and end of contract review. Where we are asked which stages of the procurement process we consider modern slavery risk at, our answer is: all of the above.

3.4 Our Standards for Worker Treatment

In line with the Ethical Trading Initiative Base Code and the Employer Pays Principle, we require 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 on reasonable notice, without penalty; workers have freedom of movement; workers are free to join or form a trade union or other worker representative body, and to bargain collectively; no worker is subject to violence, harassment, intimidation, or abuse; no worker is charged recruitment fees; overtime is voluntary; no child labour is used, and we verify the age and right to work of every worker we supply; no worker is discriminated against on any protected characteristic; no worker’s original identification or travel documents are confiscated, withheld or retained; and victims of modern slavery are provided with access to remedy, compensation and justice (see Section 7). We will not knowingly do business with any supplier, agent, or organisation in our supply chain that fails to meet these standards.

4 Our Performance

As part of monitoring the performance of Engage Education, we track the following key performance
indicators:

• The level of training amongst our staff, and the percentage of staff who have completed modern slavery training
• The speed with which we investigate related complaints, and the effectiveness of our
  whistle-blowing procedures
• The level of compliance and transparency we have established in our supply chain, and the
  number of suppliers assessed for modern slavery risks
• Review of our Sage payroll and CRM to review our employee and candidate salaries to ensure
  they are above the national living wage, and the percentage of workers who have had right to
  work verified
• Scores and risk flags arising from MSAT or equivalent client assessments, and the time taken to
  resolve any resulting action points
• Completion of the annual senior-leadership review of the effectiveness of our whistleblowing and grievance mechanisms, and the number of improvements made as a result
• Completion rates for our termly candidate satisfaction surveys, and the number and nature of any concerns raised through them
• The percentage of suppliers who sign up to an appropriate code / provide their own modern
  slavery statements

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as
necessary. The Board of Directors endorses this statement and is fully committed to its implementation.

We also measure our effectiveness by reviewing any reported concerns, near misses or safeguarding alerts related to exploitation and assessing whether appropriate corrective actions have been taken and recorded. We recognise that our approach to measuring effectiveness continues to develop as we enhance our understanding of modern slavery risks in our business and supply chains, and we are committed to strengthening our monitoring processes and expanding our key performance indicators as our capabilities mature.

5 Our Training

All of our staff receive training and support that is appropriate to their role. In particular:

• Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
• Our recruiters 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.

As part of this, our staff are encouraged to discuss any concerns that they have. Training is refreshed
annually, and training content is reviewed annually to ensure it reflects current risks within our business and supply chain. Staff in higher-risk roles, such as those working directly with candidates or conducting overseas recruitment, receive enhanced guidance on identifying indicators of exploitation.

6 Grievance Mechanisms, Reporting and Our Service Level Agreement

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.

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 in a language they understand.

We operate the following Service Level Agreement for responding to reports: we will acknowledge receipt 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 within 5 working days of the investigation concluding. Urgent reports involving an immediate risk to a worker’s safety are fast-tracked.

In addition to investigating individual reports, our Board of Directors reviews 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 approves any resulting improvements.

7 Remediation and Support for Victims

If we identify modern slavery in our business or supply chains, we are committed to taking appropriate remedial action with the safety and well-being of victims as our priority. We will immediately ensure the safety of any victims identified, report to appropriate authorities, including the Police, the Modern Slavery Helpline and the Gangmasters and Labour Abuse Authority, and preserve evidence for investigation. We will provide victims with information about support services, ensure victims are not penalised or disadvantaged, respect victims’ wishes regarding reporting to authorities, and ensure victims receive any wages owed.

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. Instead, 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, the root cause of the incident, the corrective action to be taken and by whom, and a realistic delivery timeframe. We expect our suppliers to apply this same graduated, action-plan-led approach to their own subcontractors. We will terminate a supplier relationship only where the supplier is unwilling or unable to deliver an agreed corrective action plan, or fails to remediate within the agreed timeframe, and will share information with other businesses and industry bodies where appropriate.

8 Governance and Accountability

The Board of Directors has overall responsibility for ensuring our Modern Slavery Policy and this statement comply with our legal and ethical obligations, and that all those under our control comply with them. The Board reviews this statement annually and approves any updates.

Day-to-day responsibility for implementing our policies and monitoring their use and effectiveness is
delegated to Joseph Raffell, Associate Director for Compliance and Safeguarding, and Bejal Bhudia,
Financial Director. These individuals have responsibility for conducting risk assessments, implementing due diligence processes, investigating concerns, reporting to the Board, ensuring training is delivered, and monitoring KPIs.

We report on our modern slavery performance quarterly to senior management, publish this statement annually on our website, and report to regulatory bodies, including REC, GCA and FWA as required.

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. In addition, we carry out weekly internal audits of payroll and maintain internal control measures covering national minimum wage adherence and right-to-work checks throughout the hiring process. We also carry out termly surveys of candidates to assess worker satisfaction and identify any concerns about their treatment or working conditions, with results reviewed by our Associate Director of Compliance.

9 Continuous Improvement

We are committed to continuously improving our approach to preventing modern slavery. Our objectives for 2026/2027 include: defining a formal methodology, frequency and scope for our supplier audit programme; setting explicit targets against our key performance indicators and confirming senior leadership review of them; enhancing our risk assessment process to include more detailed analysis; developing partnerships with anti-slavery organisations; improving data collection on worker vulnerabilities; conducting a comprehensive review of our international recruitment processes; implementing additional checks for workers from higher-risk countries; and enhancing our whistleblowing procedures to make reporting easier.

Our long-term goals are to achieve industry-leading standards in ethical recruitment, eliminate modern slavery from our supply chains, support industry-wide improvements in preventing exploitation, and contribute to research and policy development on modern slavery.

10 Contact and Reporting

If you have concerns about modern slavery in our business or supply chains, you can report them
internally to your line manager, Joseph Raffell at joseph.raffell@engagepartners.co.uk or on 0203 510
2222, or Bejal Bhudia, Financial Director. You can also report externally to the Modern Slavery Helpline on 0800 0121 700, which operates 24/7 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. All reports will be taken seriously and investigated promptly in line with the Service Level Agreement set out in Section 6, and you will not suffer any detriment for reporting concerns in good faith.

For questions about this statement or our approach to modern slavery, please contact Joseph Raffell, Associate Director for Compliance and Safeguarding, at joseph.raffell@engagepartners.co.uk, by phone on 0203 510 2222, or by mobile on 077 1448 0919. You can also write to us at Engage Education Limited, 45 Clarendon Road, Watford, WD17 1SZ. Our company registration number is 08133749 and our main telephone number is 0333 800 7800. Our website is www.engage-education.com.

Annex A – definitions contained in the Modern Slavery Act 2015

Section 1 – Slavery, servitude and forced or compulsory labour

(1) A person commits an offence if—

(a) the person holds another person in slavery or servitude, and the circumstances are such that the person knows or ought to know that the other person is held in slavery or
servitude, or
(b) The person requires another person to perform forced or compulsory labour and the
circumstances are such that the person knows or ought to know that the other person is
being required to perform forced or compulsory labour.

(2) In subsection (1) the references to holding a person in slavery or servitude or requiring a person to perform forced or compulsory labour are to be construed in accordance with Article 4 of the Human Rights Convention.

(3) In determining whether a person is being held in slavery or servitude or required to perform forced or compulsory labour, regard may be had to all the circumstances.

(4) For example, regard may be had—

(a) to any of the person’s personal circumstances (such as the person being a child, the
person’s family relationships, and any mental or physical illness) which may make the
person more vulnerable than other persons;
(b) to any work or services provided by the person, including work or services provided in
circumstances which constitute exploitation within section 3(3) to (6).

(5) The consent of a person (whether an adult or a child) to any of the acts alleged to constitute
holding the person in slavery or servitude, or requiring the person to perform forced or compulsory labour, does not preclude a determination that the person is being held in slavery or servitude, or required to perform forced or compulsory labour.

Section 2 – Human trafficking

(1) A person commits an offence if the person arranges or facilitates the travel of another person (“V”) with a view to V being exploited.

(2) It is irrelevant whether V consents to the travel (whether V is an adult or a child).

(3) A person may, in particular, arrange or facilitate V’s travel by recruiting V, transporting or
transferring V, harbouring or receiving V, or transferring or exchanging control over V.

(4) A person arranges or facilitates V’s travel with a view to V being exploited only if—

(a) the person intends to exploit V (in any part of the world) during or after the travel, or
(b) the person knows or ought to know that another person is likely to exploit V (in any part of the world) during or after the travel.

(5) “Travel” means—

(a) arriving in, or entering, any country,
(b) departing from any country,
(c) travelling within any country.

(6) A person who is a UK national commits an offence under this section regardless of—

(a) where the arranging or facilitating takes place, or
(b) where the travel takes place.

(7) A person who is not a UK national commits an offence under this section if—

(a) any part of the arranging or facilitating takes place in the United Kingdom, or
(b) The travel consists of arrival in or entry into, a departure from, or travel within, the United Kingdom.

Section 3 – Meaning of Exploitation

(1) For the purposes of section 2, a person is exploited only if one or more of the following
subsections apply in relation to the person.

Slavery, servitude and forced or compulsory labour

(2) The person is the victim of behaviour—

(a) which involves the commission of an offence under section 1, or
(b) which would involve the commission of an offence under that section if it took place in England and Wales.

Sexual exploitation

(3) Something is done to or in respect of the person—

(a) which involves the commission of an offence under—

(i) section 1(1)(a) of the Protection of Children Act 1978 (indecent photographs of children), or
(ii) Part 1 of the Sexual Offences Act 2003 (sexual offences), as it has effect in England and Wales, or

(b) which would involve the commission of such an offence if it were done in England and Wales.

Removal of organs, etc

(4) The person is encouraged, required or expected to do anything—

(a) which involves the commission, by him or her or another person, of an offence under
section 32 or 33 of the Human Tissue Act 2004 (prohibition of commercial dealings in
organs and restrictions on the use of live donors) as it has effect in England and Wales, or
(b) which would involve the commission of such an offence, by him or her or another person, if it were done in England and Wales.

Securing services, etc, by force, threats or deception

(5) The person is subjected to force, threats or deception designed to induce him or her—

(a) to provide services of any kind,
(b) to provide another person with benefits of any kind, or
(c) to enable another person to acquire the benefits of any kind.

Securing services, etc, from children and vulnerable persons

(6) Another person uses or attempts to use the person for a purpose within paragraph (a), (b) or (c) of subsection (5), having chosen him or her for that purpose because:

(a) he or she is a child, is mentally or physically ill or disabled, or has a family relationship
with a particular person, and
(b) An adult, or a person without the illness, disability, or family relationship, would be likely to refuse to be used for that purpose.

Useful Links & Resources

● The Modern Slavery Act 2015
● The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015
● The Home Office’s Modern Slavery website contains guidance for employers on how to spot the
signs of modern slavery, and how to report it: www.modernslavery.co.uk
● The Home Office has also published guidance on complying with the Modern Slavery Act around
transparency in supply chains.
● The REC is a supporting partner of Stronger Together, which provides guidance, training resources
and a network for recruiters, workers and their clients to tackle hidden labour exploitation in supply
chains: http://stronger2gether.org