Modern Slavery Policy
At Spectrum First Education, we are dedicated to providing University students and professionals with outstanding autism specialist support that removes all barriers to their well-being and quality of life.
We are aware of the impacts of Modern Slavery (human trafficking, cuckooing, forced servitude, slavery or labour affecting men, women and children of all nationalities, ages, and ethnicities) and are fully committed to identifying and challenging this in all forms in the work we do by:
- Upholding worker’s rights to terminate their employment freely
- Supporting those affected to be supported to raise this and seek resolution, justice & redress
- Protecting the right to freedom of movement and association
- Challenging all and any form of discrimination
- Prohibiting any forms of child labour
- Prohibiting all forms of violence, intimidation, or harassment
- Preventing unlawful seizure of employee’s original identification documents
- Prohibiting employee-paid recruitment fees
We expect the same of all the institutions, companies and individuals we work alongside and will not hesitate to respond appropriately and immediately regarding any suspected breaches of the Modern Slavery Act (UK Government, 2015). We purposefully contract local companies known to us with transparent hiring practices and work with institutions with robust and contemporary Modern Slavery policies.
We are mindful of the disparity between the UK Government’s official statistics, reporting 10,000 people in the UK being impacted by Modern Slavery (34% affecting UK nationals), and statistics published by independent organisations’ analysis of the latest police data 100,000 cases in the UK. This indicates a high number of individuals experiencing ‘hidden’ or unreported forms of abuse, a significant proportion of which are likely to be disabled, especially with additional barriers to obtaining gainful employment. As indicated in reports by The Centre for Social Justice (2020), Hestia (2021) and Nottingham University Rights Lab (2021), the impacts of Modern Slavery can be far-reaching, pervasive and often imperceptible, with many instances left unacknowledged. Working to support those with social communication differences, some of whom may be more isolated, trusting or suspectable to exploitation or coercion compared to the general population, we are mindful of the subtle or ‘hidden’ forms Modern Slavery may take.
Considering the increased likelihood of those within minority status or socially excluded groups being victims of Modern Slavery and how inequality, poverty, and barriers to accessing education exacerbate this, we are mindful of our crucial position of supporting potentially disadvantaged positions within society. As part of our dedication to improving the lives of autistic people, we must extend this specialism to consider the potential threats of Modern Slavery. Accordingly, our directors and team are especially vigilant in analysing and ensuring any potential risks to those we support and employ, especially those in employment through Access to Work schemes with the risk of concealed coercion, through control of individual’s finances, professional entrapment, abuse, or relying on difficult-to-trace chains of sub-contractors.
Compliance is managed by all managers at Spectrum First at all levels, including our third-party and supplier partnerships. Our team is highly trained to recognise and manage risk in the individuals we support. We provide continuous training and resources to support awareness and the immediate raising of any concerns. and all staff have a role in supporting this. As such, our team are vigilant in identifying any potential risk to those we support and immediately responding by raising any cause for concerns in a sensitive and confidential way. A high proportion of our team is autistic / considered not of the predominant neurotype, so the importance of raising any concerns and seeking support if they believe themselves to be subject to any form of discrimination or exploitation has been outlined.
As a company committed to the ‘Nothing about us without us’ ideology, transparency is crucial to our principles. Accordingly, any breaches within our team or observed by third parties reported to the relevant statutory agencies will be recorded and published annually. Further, we fully support proposed changes to UK Transparency & Supply Chain legislation to insist companies report any instances of Modern Slavery concerns or explain why and how they know there are none.
Tools such as Preventing Modern Slavery Toolkit, Unseen UK’s guide on how to identify different forms of abuse and The Centre for Social Justice’s reports are hugely helpful starting points by which we can use our understanding of the individual we are supporting.
We will continue to monitor and seek assurance from all we work with that Modern Slavery legislation is being followed fully, including vigilance to less visible forms of exploitation, including:
- Fear of ending employment freely
- Experiences of coercion, threat, intimidation, harassment, discrimination, or abuse (sexual, criminal, domestic, labour related)
- Obligations to carry out unpaid or underpaid work
- The use of an individual’s home, through friendship or intimidation, to store or operate businesses (i.e., cuckooing)
- Control of financial assets and original identification documents restricting freedom of movement and association
- Being uneasy about accepting money or managing own finances
- Employee-paid fees for continued employment
- Unrealistic promises of financial gain in exchange for time, or unpaid/exploitative work
- Unusual travel arrangements or working hours for their role
- Being asked to do things outside of their job description that are unlawful or place them at risk of professional or personal harm
- A lack of formal contract or ‘cash in hand’ basis work
- A lack of safety measures, training or protective equipment at work
- A lack of understanding of an individual’s contractual and financial arrangements with their employer
- Being accompanied by someone linked to their work at all times
- Employment to a larger company being managed by sub-contractors who don’t follow their client/parent companies’ Modern Slavery commitments
- Disadvantageous living arrangements, linked to expectations of unpaid labour or working and living at the same place
- Signs of poor self-care, exhaustion and/or poverty