Anti-slavery Policy

Modern Slavery and Human Trafficking Policy

This Modern Slavery and Human Trafficking Policy is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015. 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.

Global China Academy (GCA) 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 and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of 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.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. GCA expects all such persons to avoid any activity that might lead to, or suggest, a breach of this policy.

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

Training

Training on this policy forms part of the induction process for all individuals who work for us, and will include subsequent updates as required.

Monitoring

As part of our initiative to identify and mitigate risk of modern slavery and human trafficking in GCA and our supply chains, we:

▪ conduct checks regarding employees’ UK address, right to work in the UK and obtaining suitable references.

▪ ensure our staff receive fair pay rates and contractual terms

▪ ensure all procurement and purchasing is conducted in line with our policies

▪ protect whistle blowers and encourage contractors and staff to report breaches of the policy

The Modern Slavery Act 2015

The Modern Slavery Act 2015 and its explanatory notes are available at:

http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted

Overall responsibility for the policy

The Trustees of GCA have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. This policy statement will be subject to regular review and amendment as often as may be appropriate.

 Breaches of the policy

Any breach of this policy may result in disciplinary action, including dismissal of an employee for misconduct. If other persons or organisations working on our behalf violate this policy, we reserve the right to terminate our relationship with them with immediate effect.

Effective: September 2023