Modern Slavery Statement for 2020

Introduction

The Inner Circle Educational Trust (ICET) acknowledges the provisions of the Modern Slavery Act and will ensure transparency within the organisation and with suppliers of goods and services to ensure that it is compliant with the Act.  ICET will not knowingly support or deal with any business involved in slavery or human trafficking and takes responsibility for implementing this Policy Statement and its objectives.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

This statement is made pursuant to section 54(1), Part 6 of the Modern Slavery Act 2015 and constitutes the ICET’s slavery and human trafficking statement for the financial year ended 31 July 2020.

Organisational Structure

During the financial year ended 31 July 2020, ICET operated as Regent’s University London. Since the end of September 2020, when the university business was sold, the charity changed its name to the Inner Circle Educational Trust, and is no longer operating as a university, but principally as a grant-making charity.

 The charity believes that during the year in question, it had a low risk of occurrence of modern slavery issues as the business, goods and suppliers were predominately supplied from the UK market and due to its due diligence and procurement procedures. Since the disposal of the university business, the charity has had very few activities apart from grant-making, and employs no staff, and so it believes it now has minimal risk of any modern slavery issues.

Within the business

While operating as a university, all directly-employed staff were employed on standardised terms and conditions and were paid at least the London Living Wage as a minimum.

All agency staff were paid at least the London Living Wage and the relevant agency provided verification of their right to work.

The charity complied with the applicable employment laws and its obligation is to ensure fairness in the hiring and advancement of all employees, both permanent and temporary without discrimination. All staff had a personal responsibility to maintain a respectful work atmosphere, free of abusive or unprofessional conduct. The University had a full complement of HR policies and procedures which were actively adhered to. In particular, a Whistleblowing Policy was in place, which encouraged staff to raise any concerns they may have had in relation to trafficking or modern slavery.

Suppliers

A strong tendering ethos was in place in the University and due diligence was carried out on all supply contracts which were of a significant size or considered high risk. All tenderers were required to supply a copy of their Modern Slavery policy. Facilities, including security and cleaning services, ICT and catering and hospitality services were outsourced areas which are generally regarded as being more vulnerable to modern day slavery; however, we believe that this was low risk at the University and there had been no reported occurrences of slavery or people trafficking within their supply chains.

Students

Regent’s University London has a high proportion of overseas students and during the year the University had policies and procedures in place to reduce the risk of people trafficking in respect of our students. Procedures were also in place to follow up on any students who unexpectedly withdrew from the University, to check on their safety.  

Our plans for the future

Because of the reduced size of the charity and the very limited scope of its activities since September 2020, the charity has no specific plans to in relation to modern slavery and human trafficking, but will keep its policies and procedures under review.

Statement of Compliance

As a result of the work completed, we can confirm that to the best of our knowledge we are compliant with our responsibilities under the Act. We will continue to review our approach and ensure that best practice is incorporated into our policies and procedures, and into our procurement arrangements.

Approved by the Board.

Dr Diana Walford, Chair of the Board of Trustees