top of page

Modern Slavery

Modern slavery is a criminal offence under the Modern Slavery Act 2015 and encompasses slavery, servitude, human trafficking and forced labour, 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.


EFA Trust aim to prevent opportunities for modern slavery to occur within our business or supply chain, and safeguarding any customers who may be at risk. This applies to all individuals working for or with EFA Trust. in any form, including our supply chain, contractors, employees and all other business partners. 

Human Trafficking and Modern Slavery Statement 2022 - 23

This statement is made on behalf of EFA Trust and 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 period April 2021 to March 2022 and is made in conjunction with the Academy Trust’s policy in relation to modern slavery with the aim of preventing opportunities for modern slavery to occur within its business or supply chain and safeguarding any customers who may be at risk.


This statement and policy applies to all individuals working for or with Essa Foundation Academies Trust in any form, including our supply chain, contractors, employees and all other business partners. EFA Trust 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 EFA Trust'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.




Essa Foundation Academies Trust is a Multi-Academy Trust whose principle activities are the provision of primary and secondary education across two academies in Bolton.

Our approach


EFA Trust has a zero-tolerance approach to any form of modern slavery and trafficking. We are committed to acting ethically, with integrity and transparency in all business dealings and we expect our supply chain, contractors, employees and all other business partners to commit to the same, including implementing and enforcing effective systems and controls to prevent and deter modern slavery.


Our policies, documentation, and key relationships (Click here to view)


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

These include:


  • Staff Handbook

  • Equalities Policy

  • Safeguarding Children in Education Policy

  • Safeguarding page (EFA Trust Website)

  • Whistleblowing Policy

  • Finance Manual


Identifying and addressing risks


We recognise as a Trust that there are two main avenues of risk through which modern slavery could impact the organisation.


  • The first is through matters of a safeguarding nature which covers child sexual exploitation or human trafficking which can directly impact our pupils. This also potentially affects the staff of our contractors.

  • The second is our supply chain and the vendors we contract.


Procurement and supply chain


We are committed to ensuring that there is transparency in our business and our approach to tackling modern slavery is consistent with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners and we are evolving and updating our procurement and contracting processes to include specific prohibitions against the use of forced, compulsory and trafficked labour, or anyone held in slavery or servitude, whether adults or children.


We expect our suppliers to hold their own suppliers to the same high standards. The biggest risk to our organisation of falling foul of the Modern Slavery Act is through our procurement of goods and services. Whilst we cannot 100% guarantee supplier adherence with the requirements of the Modern Slavery Act we will endeavour to eliminate the risks as much as possible. We will do this by ensuring that our procurement processes, supplier code of conduct and contractual terms include specific provision relating to the Modern Slavery Act.




Modern Slavery and trafficking are both forms of abuse and therefore our safeguarding policies and procedures should be followed. All frontline employees receive multi-agency Safeguarding Children training which incorporates modern slavery. These employees have an individual responsibility for ensuring that they are familiar with the signs and indicators and that they are aware of our Safeguarding policies and procedures so that they are able to respond appropriately.

Line managers must ensure that safeguarding training is kept up to date.


Training for staff


Every member of staff is trained on the Safeguarding Policy. In addition, EFA Trust has a Whistleblowing Policy which enables those with concerns about any wrongdoing or breaches of law are able to raise these concerns in confidence without fear of disciplinary action.


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 stakeholders.

bottom of page