Anti-slavery And Human Trafficking Statement
1st April 2021 to 31st March 2022 pursuant to the Modern Slavery Act 2015
1 POLICY STATEMENT
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.
We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships.
Oxford International recognises that it has a responsibility to take a robust approach to slavery and human trafficking. This statement sets out the steps we have taken and will continue to take to ensure that slavery and human trafficking are not taking place anywhere in our own business or in any of our supply chains.
2 GROUP STRUCTURE
Oxford International Education Group (OIEG) is a provider of higher education and English language education programmes for international students that are delivered through face-to-face, digital and blended channels in the private education sector. OIEG has operations in the UK, Canada, North America, Hong Kong and China as well has having representatives in Saudi Arabia, Egypt, Bangladesh, Nigeria, Thailand, Kenya, Vietnam, Nepal, Korea, Malaysia, Indonesia, Pakistan, Russia, , Companies within the Group are:
- Bradford International College Ltd
- JIC Partnership Ltd
- OIDI Ltd
- Oxford International Education and Travel Ltd
- Oxford International Education Group Services Ltd
- LIPC Partnership Ltd
- Beijing Pathways Education Consulting Company Ltd
- BIC Partnership Ltd
- ICD Partnership Ltd
- Greenwich International College Ltd
3 OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
Oxford International has a zero tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships to implement and enforce appropriate and effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in our supply chains. Accompanying this is our Whistleblowing Policy, which provides a means for people to escalate slavery and human trafficking issues and breaches.
4 STAFF
The majority of our staff are office based and all are employed on contracts that meet or exceed current employment legislation.
We engage a small number of contractor/consultants all of whom are provided with service agreements that have been reviewed by our legal advisors.
Where we use agencies to provide staff, we only use highly reputable providers.
We therefore believe that the risk of modern slavery occurring within our employee base is very low.
5 OUR SUPPLY CHAINS
We have not identified any instance or indications that either slavery or human trafficking occurs in our supply chain. However, we acknowledge that the education sector is considered at medium risk for modern slavery and human trafficking.
We do not have complicated supply chains with extensive sub-contracting. Our supply chains consist primarily of student recruitment agents, IT suppliers, transport providers (coach, ferry, rail and airline companies), schools and universities.
Our student recruitment agents are subject to rigorous scrutiny in relation to student recruitment selection and we have KPI’s in place to ensure that students enrol on the courses they applied for and successfully complete their studies. Oxford International is a Tier 4 Sponsor with the UKVI and complies with all UK immigration requirements in order to ensure that only genuine students are recruited to study on our courses.
Our other suppliers (IT, transport, cleaning etc) have been rigorously audited on appointment and are generally long-standing suppliers of the business with whom we have had a working relationship for many years.
Additionally, all staff who regularly visit countries that may be deemed high risk for modern slavery have received the iHASCO training (see below).
6 COMPLIANCE & DUE DILIGENCE
We expect all those in our supply chains to comply with our values and expect any entity with which we do business to have suitable anti-slavery policies and processes in place.
Notwithstanding the above, Oxford International therefore plans to take the following action:
- Introduce a Supplier Code of Conduct, setting out our expectations that our supplier will provide safe working conditions, treat workers with respect and dignity and act ethically and within prevailing employment laws.
- Require all suppliers to accept standard terms and conditions to comply with applicable anti-slavery and human trafficking legislation.
- Ensure all our contractual arrangements with existing suppliers are amended on renewal to include specific provisions regarding slavery and human trafficking.
- Integrate better assessment of the modern slavery risks presented by our suppliers.
- Introduce supplier due diligence to address the risk of modern slavery.
7 COMMUNICATION AND TRAINING
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will be providing appropriate training to all staff to raise awareness and ensure they and all staff know how to recognise red flags and raise concerns. This will include online training provided by iHASCO, who currently provide the Group with other compliance training.
All staff will be made aware of this policy and how to access it as part of their induction.
Oxford International is committed to preventing slavery and human trafficking in its corporate activities.
Oxford International Anti-Slavery and Human Trafficking Policy 2021
Download PDF version here.
Policy to be reviewed March 2022