Human Trafficking, Modern Slavery and Exploitation Policy
1. Policy Statement
Datalaw fully opposes all forms of human trafficking, modern slavery, forced labour, child labour, servitude, coercion and exploitation. We are committed to protecting the fundamental human rights, dignity and safety of all Learners, Apprentices, Employees, Employers, Partners, Contractors and Suppliers.
We recognise our responsibilities under UK law, including:
- Modern Slavery Act 2015 (as amended 2024–2025)
- National Referral Mechanism (NRM) statutory guidance
- Human Rights Act 1998
- Domestic Abuse Act 2021
- Online Safety Act 2023–2024 updates
- Worker Protection (Amendment of Equality Act) Act 2024–2025
- Employment Rights (Protection from Exploitation) Amendments 2025
- ILO Conventions on forced labour and exploitation
- Safeguarding and Prevent duties (updated 2025)
Datalaw is committed to zero tolerance for trafficking, slavery, exploitation or abuse in any form; ensuring safe, fair, ethical working and learning conditions; preventing exploitation within our organisation and our supply chain; protecting vulnerable individuals, including young people, migrants, those with disabilities, and those at risk of coercion; training staff and learners to recognise and report exploitation; responding quickly and appropriately to any concerns; and working only with Employers and Suppliers who meet our ethical standards. Every individual has the right to live free from exploitation. These rights will be protected without exception.
2. Purpose and Scope
This policy applies to all Learners and Apprentices; Employees and Job Applicants; Employers and Workplace Providers; Suppliers, Contractors, Subcontractors and Consultants; and Visitors or third parties engaging with Datalaw.
The purpose of this policy is to prevent human trafficking, modern slavery or exploitation in any form; protect individuals from coercion, deception or abuse; ensure compliance with UK legislation and safeguarding frameworks; establish clear reporting procedures; raise awareness and build capability to identify indicators; and promote safe, transparent and ethical practices. This policy forms part of Datalaw’s wider commitment to Human Rights, Safeguarding, Equality, Inclusion, Prevent and Whistleblowing policies.
3. Definitions (2025–2026 Legal Standards)
Human Trafficking
The recruitment, movement, harbouring or control of individuals through force, coercion, deception or abuse of vulnerability, for the purpose of exploitation.
Modern Slavery
Situations where a person cannot refuse or leave work due to coercion, threats, control or deception.
Forms of Exploitation include:
- Forced or compulsory labour
- Sexual exploitation
- Criminal exploitation
- Domestic servitude
- Forced marriage
- Organ harvesting (as defined in law)
- Online exploitation, including grooming and fraud activity
- Labour exploitation under false contracts
- Debt bondage
Indicators of Trafficking may include:
- Excessive hours, low or withheld wages
- Confiscation of ID documents
- Isolation or restricted movement
- Signs of fear, control or monitoring
- Workers living in poor or unsafe conditions
- Recruitment through threats or deception
4. Legal and Regulatory Framework
Datalaw will comply with all relevant legislation including:
- Modern Slavery Act 2015 (amendments 2024–2025 Strengthening Supply Chain Accountability)
- Human Rights Act 1998
- Children Act 1989/2004
- Safeguarding Vulnerable Groups Act 2006
- Nationality and Borders Act adjustments relating to trafficking victims (2024–2025)
- UK Strategy on Modern Slavery and Human Trafficking 2025
- Employment Rights Act (Prohibition of Worker Exploitation) 2025
- Equality Act 2010 (2024–2025 harassment and protection amendments)
- Online Safety Act 2023/24 (protection from digital exploitation)
- Prevent Duty Guidance 2025 (criminal/terror exploitation links)
5. Responsibilities
Datalaw Will: ensure no form of exploitation occurs in our organisation or supply chain; conduct due diligence checks on Employers, Suppliers and Contractors; provide training for staff and learners to identify signs of trafficking; act immediately on reports of suspected exploitation; make safeguarding referrals where appropriate; record, monitor and review all reported cases; suspend or terminate relationships with any party involved in exploitation; and uphold confidentiality and protect whistle-blowers.
Managers Will: monitor working and learning environments for risks; ensure partners and suppliers comply with this policy; report concerns immediately to the Safeguarding Lead; and support employees and learners during disclosures.
Employees and Learners Must: report any concerns or suspicions; cooperate with investigations; and not engage in any practices that could lead to exploitation.
6. Prevention and Due Diligence
Datalaw will undertake mandatory checks on all new suppliers, workplace hosts and contractors; annual review of high-risk sectors (construction, retail, hospitality, manufacturing etc.); contract clauses requiring compliance with anti-trafficking laws; monitoring of labour conditions for Apprentices in the workplace; and enhanced checks for overseas recruitment or international learners. Employers failing to meet obligations may have their partnership terminated without notice.
7. Identification and Reporting of Concerns
Signs may be noticed by Employees, Learners, Employers or Partners. If trafficking or exploitation is suspected, individuals should report concerns immediately to the Safeguarding Lead, Designated Safeguarding Officer, Line Manager, or Whistleblowing Channel.
Datalaw will listen sensitively and without judgement; take immediate steps to ensure safety; report to external agencies such as the Police, National Referral Mechanism (NRM), Local Authority Safeguarding Board, and Gangmasters and Labour Abuse Authority (GLAA); record all actions securely; and not alert alleged exploiters in a way that could increase risk. No individual will face retaliation or detriment for raising a genuine concern.
8. Training and Awareness
Datalaw will provide annual mandatory training for all employees; induction training for new staff, learners and apprentices; specialist training for managers and safeguarding officers; awareness materials on signs of trafficking; and access to online and in-person reporting guidance. Training includes updates on digital exploitation, coercive control, cyber-trafficking and labour rights.
9. Safeguarding Learners and Apprentices
Datalaw recognises that certain groups may be at higher risk, including young people; migrant workers; individuals with disabilities or learning difficulties; those with language barriers; LGBTQ+ individuals; and people experiencing homelessness or financial hardship. We will conduct risk assessments for each workplace setting; ensure learners understand their rights and reporting routes; require Employers to comply fully with safeguarding and anti-exploitation duties; and remove learners immediately from unsafe environments.
10. Supply Chain and Employer Accountability
Datalaw requires all Suppliers, Contractors and Employers to sign declarations confirming compliance with anti-trafficking laws; provide safe, lawful employment conditions; allow audits or inspections where required; and maintain transparent recruitment and HR practices. Failure to comply may result in immediate termination of partnership.
11. Monitoring and Review
Datalaw will monitor reports, concerns and identified risks; review this policy annually or when legislation changes; publish a Modern Slavery Statement where legally required; conduct equality and human rights impact assessments; and report findings to the Board annually. Feedback from staff, learners, employers and partners will inform future improvements.
12. Accessibility and Alternative Formats
This policy can be provided in alternative formats or languages upon request: info@datalaw.org
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Reviewed Date |
04th December 2025 |
Next Review Due Date |
04th December 2026 |
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Reviewed by |
Sarah Parker |
Signature |
Sarah Parker |