Modern Slavery Act Statement

Brunel Academies Trust Modern Slavery Statement 2024 – 2025

This statement is made on behalf of Brunel Academies Trust (“Brunel”) (company number 11991915 [Brunel Education only]) pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. This statement relates to actions and activities during the year September 2024 – August 2025.

Brunel recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is committed to preventing slavery and human trafficking within its activities and to ensuring that its supply chains are free from slavery and human trafficking.

This statement sets out Brunel’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its business and supply chains.

Structure, business, and supply chains

Brunel is a multi-academy trust (MAT), specialising in special education needs (SEN) across Swindon and Wiltshire. The list of our Education Provisions (EP) can be found on our website: https://www.brunel.org.uk/.

Brunel has two main areas of operations:

  • A national level which oversees the business as a whole;
  • A local level – e.g., an individual academy.

Our suppliers are UK based and key supply areas cover catering, maintenance/repairs, agency workers and cleaning.

Our approach

We work to the highest professional standards and comply with all laws, regulations, and rules relevant to our business. We expect the same high standards from those we work with and are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We act ethically and with integrity in all of our charitable and business relations.

Policies, documentation, and key relationships

The following key policies and documentation detail our approach to protecting our pupils and employees from modern slavery and ensuring our supply chains are free from modern slavery.

  • Procurement and Competitive Tendering Policy
  • Complaints Policy
  • Anti-Fraud, Corruption, and Bribery Policy
  • Whistleblowing Policy
  • Single Central Record (SCR)
  • Personnel Files
  • Safer Recruitment Policy
  • Managing Allegations and Low-Level Concerns Policy
  • Filtering and Monitoring Policy
  • Child Protection and Safeguarding Policy
  • Visitor Management Policy
  • Code of Conduct
  • Supplier terms and conditions

In addition, we regularly monitor and review risk by improving employee working and pay practices.

Our Risk and Audit Committee has overall oversight of the process and practices embedded within Brunel to reduce Modern Slavery and in ensuring our supply chains, which rely on people, can demonstrate adherence with local and national laws and regulations, including paying the minimum wage. The members of the Committee work together with the People and Culture Committee as appropriate on these areas.

Identifying and addressing risks

We recognise as a Trust that there are two main avenues of risk through which modern slavery could impact Brunel. The first is through matters of a safeguarding nature which covers child sex exploitation or human trafficking which can directly impact our pupils. This also potentially affects the employees of our contractors. The second is our supply chain and the vendors we contract.

Supply chains

Our supply chains are drawn mainly from the catering, cleaning, estates management and education sectors, all based within the UK. We procure goods and services from third party providers predominantly based within the UK.

Safeguarding

We take safeguarding incredibly seriously in upholding our statutory duties and striving to safeguard employees and pupils through a positive culture of safeguarding in everything we do. We have a Trust Safeguarding Lead as well as Designated Safeguarding Leads and deputies in every EP. Collectively, and alongside the People Services Team, these colleagues work together to implement policy and secure excellence in safeguarding practice across the Trust. Each EP proactively works with the local authorities, the local safeguarding partnerships, the LADO (Local Authority Designated Officer) (now just LADO as Wiltshire have no longer use DOFA) and local stakeholders to address safeguarding concerns, including child sexual exploitation and human trafficking. Good practice is shared amongst the EPs through safeguarding training and best practice meetings that always include information about early identification of those at risk of abuse and exploitation.

The quality and impact of our safeguarding practice is reviewed at every level of Trust governance. Safeguarding policy and practice are reviewed at board level.

Statutory safeguarding practices and impact on keeping children safe are reviewed and audited by the Trust Safeguarding Lead.

Safeguarding is an agenda item at every Board of Trustees Meeting, and we have a named Trustees with portfolio responsibility for Safeguarding.

Our Brunel Safeguarding Policy is reviewed annually by the Executive Leadership Team and the Board of Trustees. It is fully compliant with all statutory requirements and guidance set out in Keeping Children Safe in Education (DfE 2024).

Training

Every employee, whether or not they are based in an EP, is trained on the policy (either in person or via e-learning) and is required to declare annually that they have read and understood the policy and their training. In addition, Brunel also has a Whistleblowing Policy which enables those with concerns about any wrongdoing or breaches of law, to raise these concerns in confidence without fear of disciplinary action.

We are fully satisfied that through our robust safeguarding training that employees could identify and act appropriately for at risk pupils, employees, and contractors.

This is not an area for complacency however and we keep under closely scrutiny and evaluation our safeguarding policy and practice. We evaluate our processes for raising concerns to ensure that there are clearly identified ways to report concerns of whistleblowing or modern slavery which are available to all users of our sites.