Governance
Modern Slavery
The Learning Community Trust
is committed to continuously improving our practices to ensure that modern slavery and human trafficking are not present within our own organisation or our supply chains. We strive to act ethically and with integrity in all our activities.
This Statement is made pursuant to section 54 of the Modern Slavery Act 2015 and constitutes The Learning Community Trust’s Modern Slavery and Human Trafficking Transparency Statement as of December 2025.
Our Statement explains the steps we have taken to date and how we plan to continue developing and implementing a proactive approach to the prevention of modern slavery.
ORGANISATIONAL STRUCTURE, ITS BUSINESS AND SUPPLY CHAINS
The Learning Community Trust is a multi-academy trust responsible for overseeing and governing a group of schools. Our funding comes directly from the government rather than through the Local Authority. This means we operate more independently, giving us more control over our finances, curriculum, and other aspects of school management.
Our Trust and headquarters are mainly based within Telford & Wrekin, but we have one academy in Shrewsbury. All teams report to the CEO, who are responsible for the day to day running of the Trust and ensuring it complies with all relevant legislation. They report to the Trustees who are legally responsible for the Trust’s activities.
Our suppliers are predominantly UK-based providing us with services relating to; marketing, recruitment, venues, events, IT delivery and support, offices, agency workers, consultants, training, travel, professional services, office supplies, furniture, IT hardware and other materials used in our day-to-day operations.
POLICIES IN RELATION TO SLAVERY AND HUMAN TRAFFICKING
The Learning Community Trust is committed to continued policy development to ensure that we keep up to date with all changes in legislation, including full compliance with the Modern Slavery Act.
We have following policies that support us in ensuring we are compliant with the Modern Slavery Act:
- Safeguarding Policy
- Data Protection Policy
- Anti-Fraud, Bribery and Corruption Policies
- Whistleblowing Policy
- Grievance Policy
- Safer Recruitment Policy
- Pay Policy
- Discrimination, Harassment and Bullying Policies
DUE DILIGENCE PROCESSES
We have implemented several measures to proactively manage the risk of Modern Slavery within our Trust and supply chain:
- We have processes in place to raise, investigate and act on safeguarding concerns within the Trust.
- All our key sub-contractors are required to demonstrate adherence to employment legislation to ensure the welfare and well-being of all employees on programmes are protected.
- For all our key sub-contractors and suppliers, we carry out detailed financial and legal due diligence checks for all large supply arrangements as part of the procurement process.
- All The Learning Community Trust staff are required to complete a range of mandatory compliance training annually.
- We are an accredited Living Wage provider committed to paying the current living wage to all directly employed staff and third party contracted staff.
- For recruiting temporary workers, we utilise the services of reputable agencies with whom we have agreed Terms and Conditions for each appointment, and which are reviewed annually.
RISK ASSESSMENT AND MANAGEMENT
We manage risks in accordance with our risk-management policy. All key organisational risks are recorded on a risk register that includes an assessment of their likelihood and impact; tracks the internal controls in place and actions taken to reduce, eliminate or mitigate against them; and sets future mitigating actions that would further reduce the likelihood and impact of the risk materialising.
The Senior Leadership Team has accountability and responsibility for the risk register. The Trustee Board holds overall accountability for ensuring that effective risk management arrangements are in place. It is supported in this role by its Audit & Risk Committee which reviews risks escalated from the executive on a termly basis. A professional internal audit team are employed to undertake an annual programme of work intended to test the effectiveness of the internal control and risk management systems.
The Trust assesses and reviews areas of operations where the Act could be contravened through ongoing supply chain management. Risk is evaluated against criteria including country of origin, sector, transaction type and contractual relationship. Any suppliers identified as being from high-risk industries or locations will be reviewed and where risks are identified they will be escalated to the COO. If required, suppliers will be contacted to agree a time-bound action and improvement plan which will be closely monitored on a regular basis.
KEY PERFORMANCE INDICATORS TO MEASURE EFFECTIVENESS OF STEPS BEING TAKEN
To date, there have been no reported incidents of modern slavery by The Learning Community Trust or suppliers to The Learning Community Trust in 2024/25.
TRAINING ON MODERN SLAVERY AND TRAFFICKING
We deliver training to relevant staff on the following policies which helps support us in ensuring we are compliant with the Modern Slavery Act:
- Safeguarding Policy
- Data Protection Policy
- Anti-Fraud, Bribery and Corruption Policies
- Whistleblowing Policy
- Grievance Policy
- Safer Recruitment Policy
- Pay Policy
- Discrimination, Harassment and Bullying Policies
Approval
This statement was approved by the Board of Trustees in November 2025 and signed by Kevin Barton, Chair of the Board of Trustees, The Learning Community Trust
