NAVITAS UK HOLDINGS LIMITED modern slavery statement summary (2024)

Organisation address

The Lambourn,
Wyndyke Furlong,
Abingdon,
Oxfordshire,
United Kingdom,
OX14 1UJ

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for 5 of 6 recommended areas

What is a modern slavery statement?

UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.

Link to full statement

Go to full modern slavery statement on organisation’s website

PDF version of the statement

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NAVC240813-1107 Modern Slavery Statement FY24.pdf

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About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Contents

Organisations covered by the statement
Legal requirement to publish
Statement period and sign-off details
Recommended areas covered by the statement
The organisation’s sectors and turnover
Number of years producing statements
Policies
Training
Monitoring working conditions
Modern slavery risks
Finding indicators of modern slavery
Demonstrating progress

Organisations covered by the statement

NAVITAS UK HOLDINGS LIMITED modern slavery statement for 2024 is a group statement covering 18 organisations. See the full list of organisations covered by this statement

Legal requirement to publish

NAVITAS UK HOLDINGS LIMITED has confirmed it is required to publish a 2024 statement by law.

Statement period and sign-off details

The statement covers the following period:
1 July 2023 to 30 June 2024

The statement was signed off by:
Scott Jones (CEO)

It was approved by the board (or equivalent management body) on:
23 October 2024

Recommended areas covered by the statement

Government guidance encourages organisations to cover a range of areas in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended areas in the statutory guidance.

We asked the organisation to tell us which areas its statement covers.

Areas recommended by government guidance	Organisation’s response
The organisation’s structure, business and supply chains	Covered
Policies	Covered
Risk assessment	Covered
Due diligence (steps to address risk)	Covered
Training about modern slavery	Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time	Not covered A set of Key Performance Indicators (KPIs) to measure the effectiveness of the actions taken to identify and address modern slavery practices are in development,

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

Education and research

Turnover

Its turnover in the financial accounting year of this statement was:

£36 million to £60 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.

What does 'turnover' refer to in group statements?

If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:

1 to 5 years

How does this work for group statements?

If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.

Policy provisions we asked about	Organisation’s response
Freedom of workers to terminate employment	Included
Freedom of movement	Not included
Freedom of association	Not included
Prohibits any threat of violence, harassment and intimidation	Included
Prohibits the use of worker-paid recruitment fees	Not included
Prohibits compulsory overtime	Not included
Prohibits child labour	Included
Prohibits discrimination	Included
Prohibits confiscation of workers' original identification documents	Not included
Provides access to remedy, compensation and justice for victims of modern slavery	Not included
Other	Not included

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.

What counts as training?

We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.

Organisation’s response

The organisation told us it did not did not provide training on modern slavery during the period of the statement.

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.

We asked who the organisation engaged with	Organisation’s response
Your suppliers	No
Trade unions or worker representative groups	No
Civil society organisations	No
Professional auditors	No
Workers within your organisation	Yes
Workers within your supply chain	Yes
Central or local government	No
Law enforcement, such as police, GLAA and other local labour market inspectorates	No
Businesses in your industry or sector	No

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.

What are social audits?

A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.

Social audits we asked about	Organisation’s response
Audit conducted by your staff	Yes
Third party audit arranged by your organisation	No
Audit conducted by your supplier’s staff	No
Third party audit arranged by your supplier	No
Announced audit	No
Unannounced audit	No

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.

We asked if workers could raise concerns this way	Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app	Yes
Through trade unions or other worker representative groups	No

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:

In FY24 we continued to raise awareness of modern slavery risks among employees and established a single point of contact for employees to ask questions or raise concerns related to modern slavery.

Modern slavery risks (optional)

Warning Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.

We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

EDUCATION AGENTS: We recognise there is a risk that agents who recruit students for overseas education institutions may be directly or indirectly involved in modern slavery practices.

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your supply chains. Tier 1 suppliers Provide their products and services directly to your organisation.
Who was it most likely to affect	Organisation’s response: Migrants
In which country	Organisation’s response: No details provided
Actions or plans to address this risk	Organisation’s response: Develop improved agent selection and monitoring systems. Continue to improve our agent reporting systems to improve identification of suspicious activity. Improve agent awareness of modern slavery and human trafficking risks and inform them of their obligations and how they may inadvertently contribute to modern slavery and human trafficking. Share information on modern slavery developed specifically for students on our websites.

Priority risks for this organisation (2 of 3)

GOODS AND SERVICES: There is a potential for us to contribute to, or be directly linked to, modern slavery practices through the procurement of the goods and services used to operate our business.

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your supply chains. Tier 1 suppliers Provide their products and services directly to your organisation.
Who was it most likely to affect	Organisation’s response: Children
In which country	Organisation’s response: No details provided
Actions or plans to address this risk	Organisation’s response: Develop tools to help staff assess the risk of modern slavery practices in any goods or services to be procured. We will require enhanced due diligence before engaging with suppliers of higher risk goods and services. We will provide training to relevant staff members with procurement responsibilities. We will review our supply chain data for our suppliers of electronic equipment to understand the measures taken by these suppliers to reduce the risk of modern slavery within the supply chain.

Priority risks for this organisation (3 of 3)

EMPLOYEES: With a presence in 27 countries we consider there to be a higher risk that our staff or contractors in certain countries may be subjected to modern slavery practices.

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your own operations.
Who was it most likely to affect	Organisation’s response: Women Migrants
In which country	Organisation’s response: United Arab Emirates
Actions or plans to address this risk	Organisation’s response: We continue to work towards increasing awareness about Modern Slavery risks, the reporting tools we currently have available (Whistleblowing platform and Modern Slavery mailbox), as well as a new reporting tool. We will be developing Modern Slavery Awareness training that is specific to the education sector.

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.

What are ILO indicators of forced labour?

The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour