Modern Slavery Policy

Modern Slavery Statement Timian Learning and Development

1st June 2024

Introduction

At Timian Learning and Development, we are dedicated to upholding the highest ethical

standards in all our business practices. We firmly believe in treating everyone with

dignity and respect and are committed to preventing any form of modern slavery or

human trafficking within our operations and supply chains.

Our Organisation Structure, Business, and Supply Chains

Timian Learning and Development is a provider of learning and development solutions.

We design and deliver a wide range of training programmes, workshops, and eLearning

courses for businesses and individuals. Our supply chains include partnerships with

suppliers of educational materials, technology platforms, and professional services.

Our Policies in Relation to Slavery and Human Trafficking

We have a zero-tolerance policy towards modern slavery and human trafficking. This

commitment is embedded in our company policies, including our Code of Conduct,

Supplier Code of Conduct, and Whistleblowing Policy. These policies are regularly

reviewed to ensure they align with current legislation and best practices.

Our Due Diligence Processes

We conduct thorough due diligence on all our suppliers to ensure they share our

commitment to preventing modern slavery and human trafficking. This includes:

Assessing their risk of modern slavery and human trafficking through questionnaires

and third-party assessments. Including provisions in our contracts with suppliers that

explicitly prohibit modern slavery and human trafficking. Monitoring our suppliers’

compliance with our modern slavery and human trafficking policies through regular

audits and reviews. Taking appropriate action, including termination of contracts, with

suppliers who are found to be involved in modern slavery or human trafficking.

Risk Assessment and Management

We recognise that modern slavery and human trafficking can occur in any industry. We

have conducted a comprehensive risk assessment to identify potential areas of risk

within our own operations and supply chains. This assessment considered factors such

as the countries we operate in, the types of services we provide, and the industries we

serve. Based on this assessment, we have implemented the following measures to

manage the risk of modern slavery and human trafficking:

Providing training to our employees on modern slavery and human trafficking so that

they can identify and report any concerns. Creating a safe and supportive environment

where employees feel comfortable raising concerns about modern slavery or human

trafficking without fear of retaliation. Implementing a whistleblowing hotline that allows

employees and other stakeholders to report concerns anonymously. Regularly

reviewing our policies and procedures to ensure they remain effective in preventing

modern slavery and human trafficking.

Measuring Our Effectiveness

We measure our effectiveness in ensuring that slavery and human trafficking are not

taking place in our business or supply chains through the following performance

indicators:

  • The number of suppliers assessed for modern slavery and human trafficking risks.
  • The number of modern slavery and human trafficking concerns raised through our whistleblowing procedures.
  • The number of training sessions provided to employees on modern slavery and human trafficking.
  • The number of audits conducted on suppliers to ensure compliance with our modern slavery and human trafficking policies.

Training and Capacity Building

We provide regular training and capacity building to our staff on modern slavery and

human trafficking. This training covers:

  • How to identify the signs of modern slavery and human trafficking.
  • How to report concerns about modern slavery and human trafficking.
  • Our company’s policies and procedures in relation to modern slavery and human trafficking.

Continuous Improvement

We are committed to continuously improving our efforts to prevent modern slavery and

human trafficking. We will regularly review our policies, procedures, and performance

indicators to ensure they remain effective.

Further Information

If you have any concerns about modern slavery or human trafficking within our

operations or supply chains, please report them to your supervisor or to the Human

Resources department. You can also report concerns anonymously through our

whistleblowing hotline.

Specific Supplier References:

  • AWS: We will review AWS’s commitment to human rights and fair labour practices, particularly regarding their data centres and software development teams.
  • Hubspot: We will review Hubspot’s commitment to human rights and fair labour practices, particularly regarding their data centres and software development teams.
  • Solopress: We will assess Solopress’s policies on ethical sourcing and labour practices, particularly regarding their supply chain for paper and inks.
  • Salesforce: We will review Salesforce’s commitment to human rights and fair labour practices, particularly regarding their data centres and software development teams.
  • E-Learning LMS Platforms: We will assess the LMS provider’s policies on data privacy and security, ensuring learner data is protected and not exploited.
  • Local Accountancy Firm: While the risk may be lower, we will still enquire about their internal policies on fair employment practices and ethical conduct.

Policy Approval

This policy has been approved by the Board of Directors of Timian Learning and

Development.

  • Date of Approval: 1st June 2024
  • Signed: James Hourihan
  • James Hourihan, Director of Learning and Development
  • Timian Learning and Development