Modern Slavery Policy 2016
Slavery and Human Trafficking Statement Overview
The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 came into effect on 29 October 2015 and required commercial organizations in any sector with a turnover greater than £36m per annum to produce a Slavery and Human Trafficking Statement' for each financial year.
Introduction
This statement sets out the actions to which BARBRI Inc (“BARBRI”) understands 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 its supply chains.
The Company recognizes that it has a responsibility to take a robust approach to slavery and human trafficking. BARBRI is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.
Organizational structure and supply chains
This statement covers the activities of BARBRI and its partners in delivering legal education solutions to students and clients across the globe.
We are a part of BARBRI, and our ultimate parent company is Barbri Holdings Inc, which has its head office in the USA. BARBRI International Limited (“BIL”) operates in the United Kingdom and has a turnover in excess of the statutory threshold. BIL is aware of its responsibility under the Act and is developing its framework to ensure its supply chain complies with the Act.
Our Business
Our business is organized into the following business units:
Barbri International, which provides test preparation and admissions support for professional licensure exams and similar assessments for legal professionals.
Relevant Policies
BARBRI has, or intends to develop, policies that assist in preventing slavery and human trafficking in its operations, including:
- Bribery and other Corrupt Behaviour: The Company has a strict anti-bribery and corruption policy in line with the Bribery Act (2010).
- Code of Conduct: BARBRI’s Code of Conduct makes it clear to employees the actions and behavior expected of them when representing the organization.
- Supplier Terms & Conditions: BARBRI is committed to ensuring that its suppliers adhere to the highest standards of ethics, and a review of its Terms & Conditions will be undertaken in 2016 to ensure that suppliers are aware of their obligations under the Act and comply where necessary.
Due Diligence
Our supply chain includes student recruitment agents, IT suppliers, sub-contractors, and consultants for education services.
We internally review our supply chain to evaluate risks and review aspects of the supply chain, including but not limited to safety, human trafficking, child labor, and other legal requirements to ensure they meet their regulatory obligations.
Training
BARBRI will ensure that key staff will undertake training on modern slavery, where deemed necessary, and will engage with external training providers, as appropriate.
Awareness Raising
BARBRI will continue to raise the awareness of the basic principles of the Modern Slavery Act 2015, including but not limited to:
- How our partners can identify and prevent slavery and human trafficking.
- What employees can do to flag up potential slavery or human trafficking issues.
- What external help is available, for example, through the Modern Slavery Helpline.
- This statement will be reviewed with the Company’s leadership and employees on an annual basis.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Barbri’s slavery and human trafficking statement for the financial year ending 2016.
Sarah Hutchinson
Director of Barbri International Limited