Statement of Intent

Modern Slavery Policy

This Statement was approved by the Hemsley Fraser Group Executive Committee on 4th August 2023. It sets out our ongoing commitment to our responsibility to respect human rights and aligns with the United Nations Guiding Principles on Business and Human Rights. 

Hemsley is committed to combating modern slavery in all its forms. We recognize that modern slavery is a grave violation of human rights and a global issue that requires collective action. This Modern Slavery Statement outlines our efforts to identify, prevent, and address any risks of modern slavery within our operations and supply chains. We acknowledge our responsibility to promote ethical practices and uphold human rights, and we strive to create a transparent and accountable business environment.

Overall responsibility for the implementation and oversight of this policy rests with our Executive team and it is the responsibility of all employees and business partners to understand, support, and comply with this policy.
Signed of behalf of the Hemsley Executive Committee
Sally Hurrell
Interim CEO

Our company
Hemsley is a global learning and development provider that helps businesses improve their culture, strategy and performance through engaging learning experiences.

Founded in 1991 in the UK, the company has grown to have offices in five countries and serve clients across various sectors and industries.

We have a long-standing reputation as a world-class provider of engaging, performance-boosting and change-enabling learning and development services.

Noted especially for our digital content, learning services, leadership development and large-scale strategic solutions, we are a one-stop shop provider repeatedly chosen by clients for our innovation, agility, world-class design, and results-focused delivery.

Through the creation of learning experiences that are tailored and managed for our clients’ workforce needs, we believe that talent development, done right, can have a transformative effect on people, organizations, and the experience of work.

We operate with integrity, fairness, and respect for human rights, both within our organization and across our supply chain. We believe in treating all individuals with dignity and respect, and we work tirelessly to ensure that modern slavery has no place in our business or in the broader communities in which we operate.


What is Modern Slavery?
Modern Slavery happens when an individual is exploited by others, for personal or commercial gain. Whether tricked, coerced, or forced, they lose their freedom. This includes but is not limited to human trafficking, forced labour and debt bondage.

Modern slavery is all around us, often hidden in plain sight. People can become enslaved making our clothes, serving our food, picking our crops, working in factories, or working in houses as cooks, cleaners or nannies. Victims of modern slavery might face violence or threats, be forced into inescapable debt, or have their passport taken away and face being threatened with deportation. 

We recognise that Modern Slavery can take many forms. The most common are: 

  • Human trafficking. The use of violence, threats or coercion to transport, recruit or harbor people in order to exploit them for purposes such as forced prostitution, labour, criminality, marriage or organ removal
  • Forced labour. Any work or services people are forced to do against their will, usually under threat of punishment
  • Debt bondage/bonded labour. The world’s most widespread form of slavery. People trapped in poverty borrow money and are forced to work to pay off the debt, losing control over both their employment conditions and the debt
  • Descent–based slavery (where people are born into slavery). A very old form of slavery, where people are treated as property, and their “slave” status has been passed down the maternal line.
  • Child slavery. When a child is exploited for someone else’s gain. This can include child trafficking, child soldiers, child marriage and child domestic slavery
  • Forced and early marriage. When someone is married against their will and cannot leave. Most child marriages can be considered slavery
  • Domestic servitude. Domestic work and domestic servitude are not always slavery, and when properly regulated can be an important source of income for many people. However, when someone is working in another person’s home, they may be particularly vulnerable to abuses, exploitation, and slavery, as they might be hidden from sight and lack legal protection.


Why do we have this policy?
We want to send a clear message that Hemsley takes a stand against the exploitation of individuals and supports fair and ethical labour practices.

By fostering transparency, and requiring it across our supply chain, Hemsley can identify any high-risk areas and take appropriate actions to eradicate any potential for modern slavery.

We are committed to providing clear channels for employees, suppliers, and other stakeholders to report any suspicions or concerns related to modern slavery. We treat all reports seriously, conduct thorough investigations, and take appropriate actions to address any issues identified.

We believe that a modern slavery policy is essential to ensure we uphold ethical standards, comply with legal requirements, manage risks, safeguard our reputation, promote transparency and engage employees. By taking a robust stance to modern slavery, we aim to contribute to a more equitable and just society where there is zero tolerance of Modern Slavery.


Policy statement
Hemsley strictly prohibits all forms of modern slavery, including forced labour, human trafficking, debt bondage, and any other exploitative practices. We are committed to ensuring that our operations, employees, and business partners uphold this prohibition.

Our values
Values play a crucial role in stamping out modern slavery. Modern slavery, which includes practices such as human trafficking, forced labour, debt bondage and child labour, is a serious violation of human rights and a moral issue that requires collective action.

Hemsley’s values provide the moral compass and guiding principles that drive our efforts to stamp out modern slavery. By promoting human rights, empathy, and justice we work tirelessly with our employees, our clients and our Supply Chain Partners to create a world free from exploitation and slavery.

Our policies and governance

- Compliance with laws and regulations
We comply with all applicable laws and regulations related to modern slavery, including but not limited to the Modern Slavery Act, in all countries where we operate.

- Risk assessment                  
We conduct regular risk assessments to identify and evaluate the potential risks of modern slavery within our operations and supply chains. These assessments help us develop appropriate strategies and controls to mitigate any identified risks effectively.

  • Examples of risks assessed are:
  • Recruitment and adherence to our recruitment policies
  • Nature of goods and services purchased (are they sourced from industries/sectors/countries where Modern Slavery is prevalent)
  • Suppliers’ stance, policies and procedures on Modern Slavery
  • Any Whistleblowing risks/issues raised

- Our supply chain
Our total supplier spend in 2022 was £34.200m. Our partners and suppliers are diverse in the type of services and products they provide and the size of their businesses.

We maintain a transparent and responsible supply chain by assessing and monitoring our suppliers and business partners for compliance with anti-slavery standards. We expect our suppliers and business partners to share our commitment to eradicating modern slavery and adhere to ethical business practices.

Hemsley’s approach to new supplier onboarding involves assessing the service the supplier is providing to ascertain the level of modern slavery risk associated with the supplier and the service. All new suppliers go through our due diligence process by completing our Supply Chain Due Diligence Assessments, which includes specific questions on whether the supplier publishes a Modern Slavery Statement and how the Statement meets the requirements of the Modern Slavery Act 2015. The Supply Chain, Procurement and Associate Partners teams engage with the Compliance team who will advise on assessment results and supplier risk profile on a case-by-case basis.

As part of future plans, we will be further upskilling our Supply Chain, Procurement and Associate Partners teams to be able to assess, understand and manage suppliers’ modern slavery risks for themselves and to ensure we are able to provide real time reporting on the compliance of our Supply Chain.

We categorise all our suppliers as follows:

Hemsley Preferred

Full contractual, due diligence and quality assurance has been completed, checked and in date, a supplier review and audit plan is in place and the supplier has preferred rates with Hemsley or is treated as a ‘partner’.


Full contractual, due diligence and quality assurance has been completed, checked and in date.

Non-Approved/Missing Documents

Supplier documentation receipt/due diligence audit is in progress, or one element of their due diligence documentation/evidence has expired, and supplier is required to re-submit.


The supplier has not been used for over 12 months. Should the supplier require to be reactivated, due diligence and contractual conversations will need to be repeated in full.


The supplier has not met its contractual requirements or has failed/will not/cannot comply with the due diligence and so cannot be a part of the supply chain.


Supply Chain policies
Our Responsible Procurement Policy outlines Hemsley’s and our Supply Chain’s responsibilities towards all ethical, social and environmental matters and takes into account our business policies.  

We are committed to embedding consideration of human rights including modern slavery across our organization. We have a set of policies that help us manage the risk of modern slavery and human rights issues, encourage ethical behaviors, promote decent working practices across our business and supply chain and our commitment to remediation. Our suppliers are required to read and agree to our Supplier Code of Conduct Policy and support the standards set out within our Responsible Procurement Policy.

We require all Suppliers to evidence their commitment to meeting our Responsible Procurement Policy/Standards through the completion of our Supplier Quality Assurance Questionnaire which is part of Hemsley’s supplier due diligence process and ensures responses are assessed for compliance and risk. 

Supplier Audits and Reviews are carried out on an annual basis as a minimum, where, as well as discussing performance, confirmation of due diligence, labour practices and supply chain transparency is undertaken. 


1.    Supplier Code of Conduct Policy

Our Policy outlines the standards of personal and professional conduct that Hemsley Fraser expects its Suppliers to demonstrate when working on a Hemsley Fraser contract. The Policy is aimed at supporting a professional working environment that is productive, positive, enjoyable, sustainable, safe and free from harassment, discrimination and exploitation.  It also provides guidelines on how to address any circumstances that may arise which are in conflict with expected professional standards and values. This Policy also works in conjunction with our Equal Opportunities, Bullying and Harassment and Environmental Policy

2.    Responsible Procurement Policy
We are committed to minimise social, ethical, and environmental impacts of the Purchasing function. By incorporating this policy to procurement decisions, we aim to enhance positive impacts on the environment and society while creating a sustainable supply chain that meets our business requirements.

Business policies
Our general business policies that ensure that we are conducting business in an ethical and transparent manner include:

1.    Code of Conduct
Hemsley’s code of conduct reflects our commitment to building and maintaining a culture that is ethical, has integrity, and has wellbeing, inclusion, belonging and fair treatment at the heart of all we do and with all people that we interact with. We believe in trust and empowerment for all our people, and we recognise that all our people have the ability to make decisions or take action that could impact our reputation, our clients’ reputations, our suppliers and our ability to comply with all that is required of us in law. Because of this, our Code of Conduct is designed to provide a framework that our people can work within, and to help each individual understand how we can act ethically, honestly and professionally in all situations.

2.    Whistleblowing 
We encourage openness and will support whistleblowers that raise genuine concerns in good faith under this policy, even if they turn out to be mistaken.

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases it should not be necessary to alert anyone externally, however the law recognises that in some circumstances it may be appropriate for concerns to be reported to an external body such as a regulator and we ensure that should this be the case we take appropriate action.

3.    Recruitment 
Our policy is designed to ensure that there is consistency in how recruitment is managed in Hemsley and to set the expectations we have of recruiting managers and our people team.

This policy is used to document Hemsley’s approach to recruitment, selection and promotion. It outlines what employees can expect in terms of our recruitment process and the steps we will take to ensure we maintain a fair and equitable approach at all times.

4.    Anti-Bribery 
Bribery is a criminal offence, and our policy provides a coherent and consistent framework that enables our employees and all those associated with Hemsley to understand and implement arrangements to ensure it doesn’t occur. 

It also enables these individuals to identify and effectively report a potential breach. Hemsley requires all employees including those permanently or temporarily employed as well as agents, consultants, suppliers, business partners and other persons or organizations who perform a service for or on behalf of Hemsley to:

  • Act honestly and with integrity at all times
  • Comply with the spirit as well as the letter of the laws and regulations of all jurisdictions in which Hemsley operates, in respect of the lawful and responsible conduct of activities. 

Hemsley is committed to the prevention, deterrence and detection of bribery and we have a zero-tolerance towards it.

5.    Diversity, Equity, Inclusion and Belonging
Hemsley wholeheartedly supports the principle of equal opportunities for all current and potential employees and opposes all forms of discrimination or unfair treatment. We seek to ensure that the individual styles and personal characteristics of those who work for us will be valued and respected, therefore ensuring that employees have the opportunity to develop to their full potential.

We are committed to establishing and maintaining a culture where diversity is acknowledged and where all employees are truly valued, and our operations are free from discrimination, intimidation and harassment. We recognise the contribution which each individual can make to the business irrespective of their age, gender, gender alignment, marital status, family or parental status, part time status, sexual orientation, race, colour, religious belief, health, disability, neurodiversity, political opinion, citizenship status, education level, socio-economic background, ethnic/cultural/national origin, language/linguistics, and whether or not they are members of a trade union. 

Hemsley will endeavor to ensure that all of its policies, procedures and practice are in accordance with this policy, legislation and good employment practice. We continue to take measures to eliminate not only overt acts of discrimination but also requirements and practices, which are discriminatory in nature. We operate an employee led Diversity, Equity, Inclusion and Belonging (DEI&B) Community which runs educational and engagement activities to proactively promote and reinforce all DEI&B approaches and policies throughout the year. 

Training and awareness
We ensure that all employees involved in purchasing products and services from our Supply Chain understand our stance on Modern Slavery and what they can do to uphold this. 

Due diligence must be successfully completed before a Supplier is admitted to our Preferred Supplier List.
Results of audits and risk assessments are shared, and accurate records kept, ensuring that no one can inadvertently purchase from a non-approved Supplier. 

All teams involved in purchasing products and services from our Supply Chain will have undergone training in Himan Trafficking and Modern Slavery by the end of 2023 which will include how to identify risks in our Supply Chain.
Information on Human Trafficking and Modern slavery, including what to look out for, is contained in our Compulsory Reading playlist on our Employee Engagement Hub and must be read by all new employees. 

Monitoring and compliance
We encourage open communication and reporting of any concerns related to modern slavery. Our employees, suppliers, and other stakeholders are encouraged to report any suspicions, incidents, or breaches of our policies via our Whistleblowing Policy (see Section 7). We investigate all reports thoroughly and take appropriate actions, which may include termination of contracts or relationships with non-compliant parties.

Goals & Targets
By working towards the following goals, we aim to support a world free from modern slavery, where every individual is treated with dignity, respect, and equality.

  • Prevention: we will do this by raising awareness, addressing the root causes of vulnerability and promoting education and economic opportunities.
    • Target: to provide support and advice where a supplier fails to meet the required standard to enable them to improve their policies and become compliant
  • Collaboration and partnerships: sharing information, coordinating efforts, implementing effective policies, and leveraging resources to tackle this complex issue.
    • Target: to inform all clients of a suppliers non-approved status if they propose engaging the services of a non-approved supplier
  • Supply chain transparency: collaborating to identify and address any instances of forced labour or human trafficking in supply chains, promoting fair labour practices and responsible sourcing.
    • Target: to report any instances of actual or suspected Modern Slavery to the Modern Slavery Helpline
  • Monitoring and data collection: using data to inform policies, interventions, and resource allocation, enabling evidence-based decision-making and effective targeting of efforts.
    • Target: All Hemsley Preferred and Approved supplier records updated to identify Modern Slavery status to avoid the potential of using non-compliant suppliers by end of 2023