Modern Slavery Policy

Owner: Shaun Jarvis, Founder & CEO  |  Version: 1.0  |  Date: July 2026  |  Review: Annually, or following relevant legislative or operational change

1. Introduction and Commitment

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Jarvis Education Ltd has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our own business or in our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

2. Status of this Policy

The Modern Slavery Act 2015 requires commercial organisations with an annual turnover of £36 million or more to publish an annual slavery and human trafficking statement. As a small education consultancy, Jarvis Education Ltd falls below this threshold and is not legally required to publish a statement.

We have nevertheless chosen to adopt this policy voluntarily. It reflects our values and our commitment to good practice, and it gives the schools, academy trusts, local authorities and other clients we work with confidence that we share their standards on safeguarding and ethical conduct.

3. Scope

This policy applies to all individuals working for or on behalf of Jarvis Education Ltd in any capacity, including the Founder & CEO, employees, associates, education consultants, contractors, and any third parties engaged to deliver work on the company’s behalf.

It also informs our expectations of the suppliers and partners we engage, and of the clients whose settings our consultants work in.

4. Definitions

For the purposes of this policy, modern slavery includes the following:

• Slavery – the exercise of powers of ownership over a person.
• Servitude – the obligation to provide services imposed by coercion.
• Forced or compulsory labour – work or service exacted from a person under the menace of a penalty and undertaken involuntarily.
• Human trafficking – arranging or facilitating the travel of another person with a view to their exploitation.
• Child labour and exploitation – the employment or exploitation of children in a manner that is unlawful, harmful, or interferes with their education and development.

5. Legal Framework

This policy is informed by, and operated in line with, the following legislation and guidance:

• Modern Slavery Act 2015
• Keeping Children Safe in Education
• Working Together to Safeguard Children
• The Children Act 1989 and 2004
• The Employment Rights Act 1996
• The Equality Act 2010

This policy should be read alongside the company’s Safeguarding Policy, Safer Recruitment practices, and Equality, Diversity & Inclusion Policy.

6. Responsibilities

6.1 Founder & CEO

The Founder & CEO holds overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Founder & CEO also acts as the point of contact for any concern raised under this policy.

6.2 Consultants, Associates and Contractors

All consultants, associates and contractors must read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of everyone working for us or under our control. They must:

• avoid any activity that might lead to, or suggest, a breach of this policy;
• be alert to the risks of modern slavery, however small, in our business and in the settings they visit;
• report promptly any concern, suspicion or knowledge of modern slavery to the Founder & CEO.

7. Recruitment and Engagement

Jarvis Education Ltd applies safer recruitment practices to everyone it engages. These practices guard against exploitation as well as supporting safeguarding more broadly, and include:

• verifying the identity and right to work in the UK of every consultant or contractor;
• conducting enhanced DBS checks, verified and documented;
• obtaining and validating two professional references prior to engagement;
• paying all those we engage fairly and in line with agreed terms, and never below the legal minimum;
• ensuring that work is undertaken freely and that no individual is subject to coercion, withholding of documents, or unlawful deductions.

8. Supply Chains and Due Diligence

Our business operations are the provision of educational consultancy. Our supply chain is small and, in the main, UK-based, covering items such as professional services, software and office supplies. The risk of modern slavery within our direct supply chain is therefore assessed as low.

Notwithstanding this assessment, we take a proportionate approach to due diligence. We will:

• consider modern slavery risk when selecting and engaging new suppliers and partners;
• expect our suppliers and partners to comply with the Modern Slavery Act 2015 and to hold their own suppliers to equivalent standards;
• periodically review our supply arrangements and address any concerns identified;
• reserve the right to terminate our relationship with any supplier, partner or individual found to be in breach of this policy.

9. Awareness and Training

Jarvis Education Ltd ensures that those working on its behalf understand the risks of modern slavery and human trafficking and know how to act on concerns. Safeguarding training undertaken by our consultants includes content drawn from Part 1 of Keeping Children Safe in Education, which addresses indicators of exploitation, including child criminal and sexual exploitation and trafficking.

Awareness of this policy forms part of consultant induction and is refreshed in line with our annual safeguarding training.

10. Reporting Concerns

Everyone working for or on behalf of Jarvis Education Ltd is encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains, or in any setting they are working in, at the earliest possible stage.

• Concerns relating to a child, or to an adult at risk in an educational setting, must be reported to the Designated Safeguarding Lead immediately and dealt with in line with the Safeguarding Policy.
• Other concerns under this policy should be reported to the Founder & CEO.
• Where a person is in immediate danger, contact the emergency services on 999.
• Concerns may also be reported to the Modern Slavery & Exploitation Helpline on 08000 121 700.

No one will suffer any detrimental treatment as a result of reporting, in good faith, their suspicion that modern slavery is or may be taking place. We are committed to ensuring that no individual faces reprisal for raising a genuine concern.

11. Breaches of this Policy

Any breach of this policy will be taken seriously. A breach by an employee, consultant, associate or contractor may result in action under our disciplinary or engagement-termination arrangements. A breach by a supplier or partner may result in the termination of that relationship.

12. Monitoring and Review

This policy is owned by the Founder & CEO and will be reviewed annually, or sooner in response to changes in legislation, guidance or the nature of our operations.

To date, Jarvis Education Ltd has received no reports of, and is not aware of, any instance of modern slavery or human trafficking within its business or supply chains.

13. Contact

This policy is approved and owned by:
Shaun Jarvis, Founder & CEO
07984 645089
hello@jarviseducation.co.uk

This statement is made in line with the principles of section 54(1) of the Modern Slavery Act 2015 and sets out the steps Jarvis Education Ltd takes to ensure modern slavery and human trafficking are not taking place within its business or supply chains.