Modern Slavery and Human Trafficking Policy


CL Consortium Limited (trading as the Charity Learning Consortium)

1. Policy Statement

CL Consortium Limited (the “Company”, trading as the Charity Learning Consortium) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chains. We have a zero-tolerance approach to modern slavery in all its forms, and we expect the same high standards from our suppliers, contractors, and business partners.

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.

2. Purpose

This policy outlines our approach to ensuring that there is no modern slavery or human trafficking in any part of our business or our supply chains. It provides guidance to employees and other stakeholders on recognising and reporting potential concerns.

3. Scope

This policy applies to:

  • All employees of CL Consortium Limited, regardless of role or seniority
  • Contractors, consultants, agency staff, and other temporary workers
  • Suppliers and service providers working on our behalf

4. Responsibilities

    • The CEO has overall responsibility for ensuring this policy complies with our legal and ethical obligations.
    • Management is responsible for implementing the policy, ensuring staff understand it, and monitoring its effectiveness.
    • Employees are required to familiarise themselves with this policy and report any concerns they may have.

5. Our Commitments

We will:

  • Ask all Suppliers to complete our Supplier Screening Form, and supply the necessary supporting documentation
  • Include prohibitions against modern slavery and human trafficking in our contracts with suppliers
  • Communicate our expectations regarding ethical conduct and compliance with anti-slavery laws to our suppliers and partners
  • Provide training where appropriate to raise awareness of modern slavery risks
  • Maintain appropriate procedures to report and investigate concerns

6. Our Supply Chains

While our business is primarily in the provision of learning resources and services to charities, we recognise that there may be risks of modern slavery in:

  • Print and digital production
  • Technology and software services
  • Facilities management or office services
  • Professional services procured externally

We will work with suppliers to mitigate these risks, including due diligence at onboarding and contract renewal stages.

7. Due Diligence Processes

We aim to:

  • Assess supplier risk based on geography, industry, and sector
  • Include modern slavery compliance clauses in supplier agreements
  • Review suppliers periodically for ongoing compliance

8. Risk Assessment and Management

We will periodically assess the risk of modern slavery in our supply chains, taking account of:

  • The nature of the goods and services procured
  • The location of suppliers
  • Sector-specific risks 

We will take steps to mitigate any identified risks, which may include:

  • Enhanced due diligence
  • Additional contractual assurances
  • Disengaging from non-compliant suppliers

9. Training and Awareness

We will provide appropriate training to relevant employees to ensure awareness of:

  • The requirements of the Modern Slavery Act 2015
  • The signs of modern slavery and human trafficking
  • How to report concerns

10. Reporting Concerns

Employees, suppliers, and contractors are encouraged to report any concerns about suspected modern slavery in our business or supply chains. Reports can be made confidentially to:

  • Their Line Manager
  • A member of the Leadership Team
  • Via any whistleblowing procedures we have in place

We will investigate any such reports promptly and thoroughly, and we will take appropriate action.

11. Breaches of this Policy

Any employee who breaches this policy may face disciplinary action, which could include dismissal for misconduct or gross misconduct. We may terminate our relationship with suppliers and other partners if they breach this policy.

12. Review and Monitoring

This policy will be reviewed annually and updated as required to ensure it remains effective and compliant with the Modern Slavery Act 2015.

Approved by: Martin Baker
Position: CEO & Founder
Last Updated: July 2025
Next review date: June 2026

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