Modern Slavery and Human Trafficking Statement
Slavery and Human Trafficking Statement for the Financial Year ending 2023
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by BPP Holdings Limited and its group of companies, during the financial year ending 31st August 2023, to prevent modern slavery and human trafficking in its business and supply chains.
Who are we?
BPP Holdings Limited is the parent company of the BPP Education Group. This statement covers the steps taken by BPP Holdings Limited and the following companies within the BPP Professional Education Group: BPP University Limited, BPP Professional Education Limited, BPP Learning Media Limited, BPP Actuarial Education Limited, Actuarial Education Company Limited, BPP Services Limited; BPP International Limited; Estio Training Limited and Firebrand Training Limited (“BPP”).
Although not all of the companies listed above meet the reporting threshold under the Modern Slavery Act 2015, BPP is committed to ensuring that all of its businesses meet BPP’s commitment to ethical business practices. Accordingly, all listed BPP companies meet the standards set out in this statement.
Our Business
BPP provides higher education, professional education, apprenticeships and learning materials to a global community of students and clients. Details of our business operations, per company can be found below:
BPP University Limited offers degree, post graduate and apprenticeship education across its four schools: BPP University Law School, BPP University Business School, BPP University School of Technology and BPP University School of Nursing.
BPP Professional Education Limited offers professional qualifications, professional development, and apprenticeship education in a number of areas including accountancy, tax, and HR.
BPP Learning Media Limited provides learning materials and resources (in a wide choice of formats) across a broad range of vocational qualifications.
BPP Actuarial Education Limited offers actuarial apprenticeship education.
Actuarial Education Company Limited offers all non-apprenticeship actuarial education and study materials.
Estio Training Limited offers digital and tech apprenticeship education.
Firebrand Training Limited offers a wide range of IT certifications together with IT and digital apprenticeship education.
Our Commitment
BPP is committed to and supports international efforts to promote ethical business practices and policies related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking. In our Code of Business Ethics, we acknowledge responsibility under the Modern Slavery Act 2015 and will endeavour to ensure that slavery and human trafficking are not taking place within our directly employed workforce, or our supply chain.
Anti-Slavery and Human Trafficking Policy
BPP operates an Anti-Slavery and Human Trafficking Policy (the “Policy”) which applies to all individuals working for or on behalf of BPP and sets out BPP’s responsibilities (and the responsibilities of those working for and on behalf of BPP) in observing and upholding our position on preventing modern slavery. The Policy also provides guidance on how to report concerns about any issue or suspicion of modern slavery.
Due diligence processes for slavery and human trafficking
BPP’s supply chain consists of: IT Suppliers; printers (and associated couriers of learning materials); property maintenance providers; student recruitment agents; and consultants (for various education services).
All BPP suppliers are required to undergo due diligence as part of their onboarding which includes a modern slavery risk assessment. All suppliers must repeat this risk assessment at least every two years (with any higher risk suppliers being required to repeat every 18 months) in order to continue providing services to BPP.
In addition, our standard supplier contractual terms include obligations on suppliers to comply with the Modern Slavery Act 2015 and adhere to BPP’s Code of Conduct. Any breach of these principles, or the Act, will result in the immediate termination of the supplier relationship.
Whistleblowing policy
We operate a Whistleblowing Policy, aimed principally at our employees but also available to our suppliers, clients, and learners that encourages the reporting of any wrongdoing which extends to human rights violations like modern slavery. All reports are fully investigated by BPP’s internal Compliance Team, and appropriate remedial actions taken. Metrics relating to whistleblowing activity are internally reviewed.
Training
BPP provides training to all new employees on the values included in its Code of Business Ethics and receives acknowledgement of the Code from its freelancers and suppliers. In addition, all BPP staff have access to and are governed by BPP’s Anti-Slavery and Human Trafficking Policy.
As at the date of this statement, we can confirm that there have been no reported incidents of human trafficking or modern slavery within BPP or its supply chain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes BPP’s slavery and human trafficking statement for the financial year ending 31st August 2023. This statement has been approved by the Chief Executive Officer of BPP Holdings Limited on 8 July 2024.
Graham Gaddes
Chief Executive Officer
Approved and signed on 8 July 2024