Modern Slavery and Human Trafficking Statement
1. Introduction
This statement sets out Fedcap UK’s actions to identify, assess, and manage potential risks related to modern slavery and human trafficking within our operations and supply chains.
It applies to all entities and individuals working for or on behalf of Fedcap UK in any capacity, including employees, directors, officers, secondees, volunteers, interns, contractors, external consultants, business partners, and third-party representatives.
Fedcap has a zero-tolerance approach to modern slavery and human trafficking and is fully committed to ensuring transparency, ethical conduct, and compliance across all areas of the business and supply chain.
As part of our risk mitigation efforts, we maintain a range of policies, procedures, and monitoring processes designed to uphold the principles of the Modern Slavery Act 2015 and prevent exploitation in any form.
This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and reflects our commitment to continuous improvement in how we prevent modern slavery across our organisation.
The Modern Slavery and Human Trafficking Statement is reviewed annually and jointly owned by the HR and Governance teams. Oversight is provided by senior leadership, with final approval recorded in the change control log and signed off by a director.
2. Our policies
Our policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective due diligence and contractual compliance. These include:
Code of Conduct
Our code makes clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of conduct and ethical behaviour when operating and managing our supply chain. The code includes expectations around respect, integrity, fairness and whistleblowing.
Whistleblowing Policy
Fedcap encourages all its workers, customers, and business partners to report any concerns related to direct activities or the supply chain, including any suspected instances of slavery or human trafficking. Our procedures enable concerns to be raised confidentially without fear of retaliation, either via our whistleblowing email whistleblowing@fedcap.org.uk or through the independent Safecall service.
Recruitment Policy
We use only specified, reputable employment agencies and conduct due diligence on their practices before accepting any candidates. We do not allow worker-paid recruitment fees and confirm all workers are employed in line with UK law.
Safeguarding Policy
Our Safeguarding and Prevent Policy sets out our duty to protect vulnerable adults and escalate concerns appropriately. All staff receive mandatory training, which includes modules on recognising signs of modern slavery, radicalisation, and exploitation.
Equality, Diversity and Inclusion Policy
Our Equality, Diversity and Inclusion policy is in place to ensure that we treat people fairly and with respect. Fedcap’s is committed to being an Employer of Choice and we strive to create and implement our Equality, Diversity and Inclusion Strategy
3. Our supply chains and supplier adherence to our values
We expect the highest standards of conduct and probity throughout our supply chain, requiring all of our people, partners, and suppliers to act with integrity and honesty.
Our procurement processes include standard due diligence questions about modern slavery and human trafficking. We examine our supply chain using our dedicated quality assurance functions, including audit, supply chain management, legal, and risk oversight.
Fedcap has assessed its current suppliers and delivery partners and does not consider any to be high risk for modern slavery or exploitation. However, we remain vigilant and monitor suppliers through ongoing compliance reviews, regular engagement, and annual validation processes where relevant.
We will continue to work with suppliers to ensure that they meet our expected standards and comply with the requirements of the Modern Slavery Act 2015.
Understanding of Sector Risks
We recognise that modern slavery and labour exploitation risks can occur in certain workforce categories across our sector, particularly:
- Migrant workers – Risk of exploitation may be higher due to unfamiliarity with rights or immigration status. Fedcap mitigates this through safeguarding processes, staff and partner training, and ensuring all recruitment is conducted in line with UK employment law.
- Temporary or agency workers – Fedcap does not currently engage temporary or agency workers. This removes the associated risks in this category; however, we remain aware of potential risks should this change in the future.
- Recruitment agencies and labour providers – All agencies must complete our Supplier Questionnaire, which specifically asks about modern slavery policies and requires evidence of compliance.
- Subcontractors or outsourced service providers – Our delivery partners and service suppliers (e.g. facilities, IT) are subject to due diligence, annual PVT checks, and contractual compliance monitoring.
Based on our current operations, we assess the overall risk to be low, however, we remain vigilant through our procurement controls, ongoing monitoring, safeguarding processes, and annual staff and partner training.
4. Due Diligence and Supplier Oversight
All new suppliers are required to complete a Supplier Questionnaire, which includes specific questions on modern slavery and human trafficking. As part of this process, suppliers are asked to confirm whether they have a Modern Slavery Policy in place and, where available, provide a copy during onboarding.
We recognise that smaller suppliers, including SMEs and VCSEs, may not yet have a formal policy. In such cases, we take a supportive and proportionate approach, offering guidance and encouraging them to adopt suitable measures aligned with the Modern Slavery Act.
This information is assessed as part of our due diligence process before any contract is agreed. We also conduct Companies House checks and financial reviews to ensure supplier stability and minimise risk. Delivery partners undergo further annual compliance reviews, which include safeguarding and risk oversight.
We do not currently consider any of our suppliers or delivery partners to be high risk in relation to modern slavery, but we remain alert to any changes or concerns.
5. Procurement Practices and Supplier Expectations
Our procurement process incorporates ethical and compliance checks at each stage, from early market engagement through to contract management.
While we do not believe our commissioning or procurement practices place undue pressure on suppliers, we review these regularly to ensure that performance targets, pricing structures, or delivery expectations do not increase the risk of exploitation.
As part of our onboarding process, suppliers are asked to demonstrate their compliance with the Modern Slavery Act. This includes confirming whether they have a policy in place. Where suppliers do not yet have one, particularly smaller organisations, we provide support and encouragement to help them develop appropriate safeguards. This is verified through our Supplier Questionnaire before contracts are finalised.
Fedcap does not charge any recruitment or onboarding fees to individuals and does not provide accommodation, healthcare, or similar services that could result in financial dependency.
Where we engage recruitment agencies for referrals or hiring, we only work with established and reputable agencies who meet our procurement standards. We do not engage agencies that require worker-paid recruitment fees.
As such, we assess the risk of debt bondage across our own operations and supplier arrangements as very low. This is monitored periodically through contract reviews and supplier engagement.
We expect all our suppliers to hold their own suppliers to the same high standards on preventing modern slavery and human trafficking.
6. What we do
As part of our commitment to preventing modern slavery and human trafficking, Fedcap Employment undertakes a range of actions to mitigate risk across our organisation and supply chain. These include:
- Delivering mandatory training to all staff and delivery partners on the Modern Slavery Act and the Prevent Duty. This training covers how to identify signs of exploitation and how to escalate concerns through appropriate channels.
- Embedding anti-slavery checks throughout our procurement and due diligence processes. All new suppliers must complete a Supplier Questionnaire confirming their compliance with the Modern Slavery Act and providing a copy of their Modern Slavery Policy.
- Maintaining clear policies and reporting mechanisms, including our Whistleblowing and Safeguarding Policies, which enable concerns to be raised confidentially and without fear of reprisal.
- All employees are subject to right to work checks and, where applicable, DBS checks as part of our safeguarding and recruitment processes.
- Monitoring training compliance and supplier engagement through our HR and governance frameworks, with annual reviews conducted by the HR and Governance teams.
- Reviewing and updating this statement annually to meet the requirements of Section 54(1) of the Modern Slavery Act 2015
7. Monitoring and Training
We monitor compliance with our modern slavery requirements through our internal governance and contract management processes.
All employees and delivery partners are required to complete Modern Slavery and Prevent training on an annual basis.
This training ensures our people and partners understand how to recognise and respond to signs of modern slavery or exploitation. Completion rates are reviewed regularly.
8. Reporting and Escalation
Fedcap has clear routes for employees, suppliers, and partners to report concerns related to unethical or unlawful conduct, including suspected modern slavery. These routes are set out in our Whistleblowing and Safeguarding Policies.
Reports of modern slavery are treated as a priority and responded to within 24–48 hours. Where appropriate, concerns are escalated immediately to our safeguarding and legal teams, with referrals made to relevant authorities or specialist support agencies.
Our approach is prompt, proportionate, and centred on protecting potential victims. We do not automatically terminate contracts with suppliers who disclose issues if they are actively cooperating with us and implementing corrective actions.
Where victims of modern slavery are identified, including underage workers, we follow our Safeguarding Policy and all relevant statutory procedures to ensure their safety, protection, and ongoing welfare.
9. Collaboration and Continuous Improvement
We are open to collaborating with peer organisations, sector partners, and third-sector bodies to strengthen our modern slavery prevention activities and share good practice.
Our zero-tolerance approach to modern slavery is communicated to all suppliers, partners, and contractors at the outset of our relationship and reinforced where appropriate.
This statement, and all related policies and processes, will be reviewed annually in line with government guidance and internal review schedules.
10. Approval
This statement has been approved by the Director of People.
Document control
| Version | Date reviewed / edited | No change / Change details | Author / Editor / Reviewer | Approved by (if required) | Approval date (if required) | Next review date |
|---|---|---|---|---|---|---|
| 1.0 | 01/03/2019 | New PolicyHR | HR | Director of People | 01/03/2019 | March 2020 |
| 1.1 | 20/03/2020 | No change – annual review | HR | Director of People | 20/03/2020 | March 2021 |
| 1.2 | 15/01/2021 | No change – annual review | HR | Director of People | 15/01/2021 | March 2022 |
| 1.3 | 20/03/2022 | No change – annual review | HR | Director of People | 20/03/2022 | March 2023 |
| 1.4 | 21/03/2023 | No change – annual review | HR | Director of People | 21/03/2023 | March 2024 |
| 1.5 | 19/02/2024 | No change – annual review | HR | Director of People | 19/02/2024 | February 2025 |
| 1.6 | 10/01/2025 | No change – annual review | HR | Director of People | 10/01/2025 | September 2025 |
| 1.7 | 11/08/2025 | Full update to align with MSAT improvements | HR | Director of People | 30/09/2025 | September 2026 |