Anti-Modern Slavery and Human Trafficking Policy

1. Commitment and scope

The Association does not tolerate modern slavery or human trafficking. This policy applies to directors, staff, contractors, trainers, volunteers and members when acting for, delivering services to or representing the Association. It also informs how the Association selects and manages suppliers and partners.

Modern slavery can include slavery, servitude, forced or compulsory labour, trafficking, debt bondage, deceptive recruitment, restriction of movement, withholding identity documents, threats and other severe exploitation. It may occur without visible physical restraint.

2. Legal status

Section 54 of the Modern Slavery Act 2015 requires qualifying commercial organisations carrying on business in the UK, with annual global turnover of at least £36 million, to publish an annual slavery and human-trafficking statement. This policy is an operational commitment and must not be represented as a statutory section 54 statement unless the Association confirms that the legal criteria and approval requirements are met for the relevant financial year.

Whether or not the reporting threshold applies, criminal, employment, safeguarding, immigration, procurement and human-rights obligations may still be relevant. People working internationally must comply with applicable local law as well as this minimum professional standard.

3. Standards for work and engagement

• work must be freely chosen and people must be able to leave in accordance with lawful contractual terms;
• no person may be required to surrender a passport, identity document, bank card or wages as a condition of work;
• recruitment fees, deposits, debt arrangements or threats must not be used to bind a person to work;
• terms, payment, hours and responsibilities should be clear, lawful and understood;
• young people and adults at risk must receive appropriate safeguarding protection;
• concerns raised honestly must not result in retaliation.

4. Suppliers, trainers and partners

The Association will apply checks proportionate to the value, location and risk of a relationship. Higher-risk indicators may include labour-intensive services, complex subcontracting, recruitment across borders, unusually low pricing, opaque ownership or operations in sectors and places associated with exploitation.

• prospective suppliers and partners may be asked about labour standards, subcontracting and modern-slavery controls;
• contracts may require compliance, reporting, access to relevant information and corrective action;
• the Association will not rely solely on warranties when credible warning signs exist;
• termination will be considered where serious abuse is substantiated or remediation is refused, while avoiding abrupt action that may increase danger to affected workers.

5. Warning signs and reporting

Warning signs can include fear or control by another person, restricted movement, excessive working hours, withheld pay or documents, debt to a recruiter, unexplained transport or accommodation arrangements, threats, inconsistent accounts or inability to speak privately. A warning sign is not proof and must be handled carefully.

Concerns connected with Association activity should be reported promptly to AssociationforIEMT@gmail.com or under the Whistleblower’s Charter. Do not confront a suspected controller or take action that may increase risk. Call 999 if someone is in immediate danger. Safeguarding concerns follow the Safeguarding Policy.

6. Response and remediation

1. Assess immediate danger, safeguarding needs and conflicts of interest.
2. Protect confidentiality and record facts separately from assumptions.
3. Seek specialist or legal advice and refer to competent authorities where necessary and lawful.
4. Consider the wishes, safety and potential consequences for affected people.
5. Preserve relevant evidence without conducting an unsafe private investigation.
6. Address contractual, governance and disciplinary issues through the appropriate fair process.
7. Record learning and strengthen controls where a weakness is identified.

7. Training, records and review

People with procurement, management, safeguarding or complaint-handling responsibilities should receive information proportionate to their role. Records will be access-controlled, accurate and retained only as long as justified under the Data Protection and Online Privacy Policy.

Current government guidance is available through GOV.UK’s modern-slavery statement guidance. This policy should also be read with the Safeguarding Policy, Whistleblower’s Charter and Membership Disciplinary Policy.

Policy owner: The Association for IEMT Practitioners Ltd. Review following material legal, organisational or supply-chain change, and otherwise at least every two years.