Modern Slavery & Human Trafficking Policy

This statement sets out New Wave Learning’s (NWL) 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 own business, and our aim to be aware of any potential modern slavery risks in any of the organisations that we may work with for any other purpose and to report any possible occurrences.  

As part of the training sector, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.


Slavery is illegal and a violation of human rights.  There are many forms of Modern Slavery including; forced labour, child labour, exploitation, being controlled by an employer, debt bondage, being physically constrained, being sold or treated as a commodity and having restrictions on freedom by being exploited by another for personal or commercial gain.  

NWL has a zero-tolerance approach to Modern Slavery.  We are committed to acting ethically and with integrity in all our business dealings and relationships.   

We are committed to ensuring our business is transparent, as such we will comply with the disclosure obligations under the Modern Slavery Act 2015.  

This policy applies to all persons working for, or on behalf of NWL Ltd, in any capacity.  This includes but does not limit the policy applicability to; employees, temporary staff, contractors and third-party representatives.  

This policy does not form part of any employee’s contract of employment and we reserve the right to amend it at any time.  


The NWL Ltd Leadership Team has overall responsibility for ensuring this policy complies with NWL legal and ethical obligations, and that all those under our control comply with it.  

 Our Managing Director has primary responsibility for implementing this policy.  This includes responsibility for the monitoring of its use and effectiveness.  Our Managing Director is also responsible for updating the policy to reflect any changes in legislation.  

 NWL Ltd employees are invited to comment on this policy and suggest ways in which it might be improved.  Comments, suggestions, and queries are encouraged and should be addressed to the Managing Director.   

Compliance with the Policy  

You must ensure that you read, understand, and comply with this policy. 

All NWL employees are responsible for the prevention, detection, and reporting of Modern Slavery in any part of our business, or any other business that we work with.  Employees are required to avoid any activity that might lead to a breach of this policy and the Modern Slavery Act 2015.  

You must notify you Line Manager as soon as possible if you believe or suspect that a conflict with, or breach of, this policy has occurred, or may occur, in the future.   

 Employees are encouraged to raise concerns about suspicions of Modern Slavery in any parts of the business at the earliest possible stage. 

Communication and Awareness of this Policy 

This policy is available in the shared NWL drive.  

Modern Slavery training, which includes identifying signs of Modern Slavery and reporting suspicions of Modern Slavery with NWL Ltd, this forms part of the induction process for employees.  Refresher training will also be provided as necessary.   

Breaches of this Policy 

Any employee who breaches this policy will face disciplinary action.  This could result in action up to dismissal in accordance with the NWL Conduct Policy.  We may terminate our relationship with other employees, suppliers and any other associates working with NWL if they breach this policy.