Introduction

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and outlines the steps that Emel Training has taken and is continuing to take to identify, prevent, and mitigate the risk of modern slavery and human trafficking within our operations and supply chains.

Emel Training is committed to operating responsibly, ethically, and with integrity in all our business relationships. We have a zero-tolerance approach to slavery and human trafficking.

Our Organisation

Emel Training is a UK-based provider of educational services and training programs working across Greater Manchester, Lancashire and select parts of the UK. We employ approximately 6 staff and work with a network of suppliers, contractors, and partners.

Our Supply Chains

Our supply chains include sourcing suitable venues to deliver courses and training from. We recognise that certain sectors and geographies carry higher risks of modern slavery, and we are committed to ensuring our supply chain is free from forced labour, slavery, and human trafficking.

Policies and Governance

We have implemented the following policies and procedures to prevent modern slavery:

• Anti-Slavery and Human Trafficking Policy

• Whistleblowing Policy

• Recruitment Policy (ensuring all employees have the right to work and are paid fairly)

These policies are regularly reviewed and communicated to relevant staff and suppliers.

Due Diligence Processes

To identify and mitigate the risk of modern slavery, we:

• Conduct risk assessments on new suppliers and partners

• Require suppliers to confirm compliance with the Modern Slavery Act

• Include anti-slavery clauses in contracts where appropriate

• Monitor high-risk areas of our supply chain

Training and Awareness

We provide training to key employees on the risks of modern slavery and how to spot potential warning signs. Ongoing awareness campaigns ensure all staff understand the importance of vigilance and ethical conduct.

Complaints Policy

A complainant may be a learner, prospective learner, funding partner, referring organisation or any other interested party that indicates dissatisfaction with the quality of service they have received. 

All complaints will be taken seriously and dealt with impartially. All staff have a responsibility for receiving complaints and dealing with them promptly and courteously in accordance with the procedure set out below.

Formal Complaints – Stage 1 of the Complaints Procedure

Formal complaints are submitted to the Quality Management Team and are overseen by the Managing Director.

An initial response to the complaint will be sent to the complainant, or to their representative, within 2 working days.

The complaint process will be managed by the Quality Management Team, where a nominated member will take responsibility to fully investigate the matter and provide the complainant or their representative with a formal response within 5 working days.

If for any reason it is not possible to provide a formal response within 5 working days, the complainant will be informed as to the reason for the delay and kept informed of the progress of the investigation.

Appeals – Stage 2 of the Complaints Procedure

Should the complainant wish to appeal against the outcome of Stage 1, they should submit their appeal in writing, within 10 days of the Stage 1 outcome.

Stage 2 appeals may involve a face-to-face meeting with the complainant and their representative (where requested).

Following the outcome of the appeals stage, a formal response will be sent to the complainant.

Monitoring of Complaints

We monitor all complaints carefully, maintaining a central complaints log file.  An annual report on complaints is produced by the Quality Management Team, detailing issues raised, timeliness of resolution and any subsequent actions.

This Complaints Policy is made known to all our staff including all Emel Training consultants, trainers, assessors and all learners and stakeholders.

Data Retention Policy

Policy Statement

This company Policy has been designed to help and encourage all employees to achieve and maintain expected standards of conduct.  It applies to all employees and anyone else working for the Company, and its aim is to ensure consistent and fair practice.

This document does not form part of your Contractual Terms and Conditions of employment and the Company may at any time amend it without consultation or prior notice.

Purpose and Scope

Emel Training Ltd (the Company) is committed to managing and handling personal data in line with best practice and data protection principles. As such this Policy details the procedures to use to ensure timely and secure disposal of documents and records that are no longer required for business purposes.

The Company holds a wide variety of personal data, from employees, workers, volunteers and contractors, as well as financial data, HR data, marketing data, client and learner data and so on, many of which include personal data. This data is held in various formats including; letters, emails, contracts, forms, software systems in both hard copy and electronic form.

It is essential that this policy is adhered to, as premature destruction of documents could result in an inability to defend claims, business difficulties and failure to comply with data protection legislation, whilst appropriate destruction and disposal will ensure that the storage space is maximised and we are not keeping documents for an unnecessarily long period of time which would breach data protection legislation.

This policy applies to all the information held by the Company and also any personal data that may be held by data processors (service providers) where they are processing information on the Company’s behalf.

Everyone is responsible for ensuring that the records that they create/maintain are accurate, maintained and disposed of in accordance with this policy. It is recognised that the documentation created and maintained by the Company will change over time and therefore this policy should be viewed as a living document and it will be reviewed on an annual basis, or sooner, as necessary.

This policy should be read in conjunction with the Data Protection Policy.

Retention 

Appendix 1 details the retention periods for specific types of documents and records.

Destruction/Disposal 

Hard copies of confidential documents or personal data should be disposed of using either confidential waste bins or shredded. Under no circumstances should any personal or confidential data be disposed of in any other manner, as this would potentially breach data protection legislation.

Disposal of documents which do not contain personal data or confidential information can be disposed of in any bin, or by recycling or by electronic deletion in the case of electronic documents.

Records of disposal should be maintained, recording the document disposed of, date and the individual responsible for authorising the disposal.

If you feel that you have been unfairly treated or discriminated against in your workplace or by a member of Best Practice’s own staff, then please put your complaint in writing.

Equality, Diversity & Inclusion Policy

Purpose                                                                

This policy sets out Emel Training’s approach to equality, diversity and inclusion. Emel Trainings committed to promoting equality, diversity and inclusion, and promoting a culture that actively values difference and recognises that people from different backgrounds and experiences can bring valuable insights to the workplace and enhance the way we work. Emel Training aims to be an inclusive organisation, committed to providing equal opportunities throughout employment and for the learners we support - including in the recruitment, training and development of employees and learners, and to pro-actively tackling and eliminating discrimination.

Equality and Diversity at Emel Training

We consider that equality means breaking down barriers, eliminating discrimination and ensuring equal opportunities and access for all groups both in employment, and to goods and services. 

We consider diversity to mean celebrating difference and valuing everyone. Each person is an individual with visible and non-visible differences and by respecting this everyone can feel valued for their contributions which is beneficial not only for the individual but for Emel Training Training too. 

We acknowledge that equality and diversity are not inter-changeable but inter-dependent. There can be no equality of opportunity if difference is not valued and harnessed.

Inclusion is the act and process of including individuals of all characteristics in the workforce and as learners of the organisation.

Scope

The rights and obligations set out in this policy apply equally to all employees, whether part time or full time on a substantive or fixed-term contract, to our learners, and also to associated persons such as contractors and others employed under a contract of service. 

All our employees have personal responsibility for the application of this policy. As part of your employee induction, you are expected to read and familiarise yourself with this policy, ensure that this policy is properly observed and fully complied with. 

Our commitment

Every employee and learner is entitled to a working/learning environment that promotes dignity, equality and respect for all. Emel Training will not tolerate any acts of unlawful or unfair discrimination (including harassment) committed against an employee, learner, contractor, job applicant or visitor because of a protected characteristic:

• Age

• Disability

• Gender reassignment

• Marriage and civil partnership

• Pregnancy and maternity

• Race

• Religion or belief

• Sex

• Sexual orientation

All employees will be encouraged to develop their skills and fulfil their potential and to take advantage of training, development and progression opportunities. Selection for employment, promotion, training, or any other benefit will be on the basis of aptitude and ability. No form of intimidation, bullying or harassment will be tolerated. If you believe that you may have suffered discrimination because of any of the above protected characteristics, you should consider the appropriateness and feasibility of attempted informal resolution by discussion in the first instance with your line manager or another colleague in a relevant position of seniority. 

You may decide in the alternative to raise the matter through Emel Training’s Harassment and Bullying and/or Grievance Policy. 

Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the appropriate procedure. Emel Training will ensure that individuals who make such allegations in good faith will not be victimised or treated less favourably by Emel Training as a result. However, false allegations of a breach of this policy which are found to have been made in bad faith will be dealt with under Emel Training’s Discipline Policy. Employees may also be personally liable for any acts of discrimination prohibited by this policy that they commit, meaning that they can be sued by the victim.

Our policy implements the legislation enshrined in the following Acts:

• The Human Rights Act 2000

• Race Relations Act 1976

•   Equality Act 2010

All staff and learners are expected to:

• Treat all individuals fairly, with dignity and respect regardless of protected characteristics

• Promote a work and education culture in which diversity is highly valued and embedded

• Ensure zero tolerance of all forms of discrimination, bullying and harassment 

• Takes steps to resolve personal conflict as early, fairly and amicably as possible 

Training Delivery

In the design and provision of training programmes, we make every reasonable effort to ensure that our conduct and materials are free from bias and will not imply discrimination or cause offence to any group or individual. We will positively promote diversity of the protected characteristics, using positive images and examples wherever possible. We will adjust learning materials where possible and practical including changing paper colour, font sizes and language.

If you feel that you have been unfairly treated or discriminated against in your workplace or in a training course by a member of Emel Training’s staff, then please put your complaint in writing.

Health & Safety Statement

Emel Training is committed to the health and safety of its learners, their colleagues and its own staff.

In-line with this commitment, Best Practice will provide guidance to employers and learners to help safeguard their health, safety and welfare at work.

Attention to health and safety in the workplace ensures that each learner is able to work in an environment that is largely free from risks to the individual’s health and safety.

Background

In the UK, the health, safety and welfare of every individual at work are protected by law. The law states that every employer has a duty to protect and keep its staff informed about health and safety. Furthermore, every employee has a responsibility to safeguard their own health and safety and that of others. This requires both employers and employees to accept responsibility for health and safety in the workplace.

Employees’ Responsibilities

As an employee, you are also responsible for the health and safety of yourself and your colleagues.

Your duties include:

• Taking reasonable care for your own health and safety and that of others who may be affected by what you do or do not do

• Co-operating with your employer on health and safety

• Correctly using work items provided by the employer, including personal protective equipment, in accordance with training or instructions

• Not interfering with or misusing anything provided for your health, safety or welfare

Funded Learners

Learners on funded programmes should report to Emel Training, all accidents resulting in three or more days absence from work or hospitalisation.

If you have any concerns about your health and safety at work, you should first discuss it with your employer, supervisor or manager or your safety representative if there is one. If your employer has not given satisfactory answers to questions you have raised, then contact the HSE or your local authority Environmental Health Department for further advice.

Further information and publications on Health and Safety are available from:

www.hse.gov.uk

Whistleblowing Policy

Emel Training offers, skills training and professional certification for a wide variety of stakeholders and learners.

Whistleblowing encourages and enables staff to raise serious concerns within the company rather than overlooking a problem or 'blowing the whistle' outside.

Staff are often the first to realise when there is something seriously wrong.  However, they may not express their concerns as they feel that speaking up would be disloyal to their colleagues or to the company.

Emel Training is committed to the highest possible standards of openness, probity and accountability. In line with that commitment we expect staff, and others that we deal with, who have serious concerns about any aspect of the organisation's work to come forward and voice those concerns.

The policy applies to all staff, (including those designated as casual hours, temporary, agency, authorised volunteers or work experience), and those contractors working for the company on our premises and the premises of our clients. 

The aims of the policy are:

• To encourage staff to feel confident in raising concerns and to question and act upon concerns about practice.

• To provide avenues for staff to raise concerns in confidence and receive feedback on any action taken.

• To ensure that staff receive a response to concerns and that they are aware of how to pursue them if they are not satisfied.

• To reassure staff that they will be protected from possible reprisals or victimisation if they have a reasonable belief that they have made any disclosure which is in the public interest. 

Types of concerns that are covered by the policy:

• Conduct which is an offence or a breach of law.

• Failure to comply with a legal obligation.

• Disclosures related to miscarriages of justice.

• Health and safety risks, including risks to the public as well as other staff.

• Damage to the environment.

• The unauthorised use of public funds.

• Possible fraud and corruption.

• Sexual, physical or other abuse of clients or learners

• Other unethical conduct.

• Actions which are unprofessional, inappropriate or conflict with a general understanding of what is rights and wrong.

NB. Other procedures are available to staff e.g. the Grievance procedure which relates to complaints about their own employment. This policy also does not replace other corporate complaints procedures which are for public use.

We recognise that the decision to report a concern can be a difficult one to make. If what you are saying is true, you should have nothing to fear because you will be doing your duty to your employer and those for whom you provide a service.

Emel Training will not tolerate any harassment or victimisation (including informal pressures) and will take appropriate action to protect staff when they raise a concern which is in the public interest.

This policy encourages you however to put your name to your concern whenever possible. Please note that:

• Staff must believe the disclosure of information is in the public interest.

• Staff must believe it to be substantially true.

• Staff must not act maliciously or make false allegations.

• Staff must not seek any personal gain.

This Whistleblowing Policy is made known to all our staff including all Emel Training  consultants, tutors and learners.

The Whistleblowing Policy is the responsibility of the Managing Director to implement.

Contacts

PROTECT (formerly PCAW)

Helpline: 020 3117 2520 (option 1)