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Modern Slavery and Human Trafficking Policy 

CTS Training welcomes the requirements of Section 54 of the UK Modern Slavery Act and sees the transparency it encourages as coherent with our support for the UN Guiding Principles on Business and Human Rights and their requirement to ‘know and show’ that we are working to respect human rights.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

As a group, we are committed to a whole organisation approach in improving our practices to combat slavery and human trafficking.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business and recognise our duty of care and responsibility to protect against any form of abuse within the training environment. We have reviewed our Safeguarding policies and procedures to assess their effectiveness in identifying, tackling, and reporting modern slavery issues.

Our Safeguarding policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are reported.


To ensure a high level of understanding of the risks of modern slavery and human trafficking across CTS we will continue to roll out relevant training to all our staff. 

Six Key Signs of Exploitation 

1.    General Indicators

Trafficking victims are often lured into another country by false promises and so may not easily trust others. They may:

•    Be fearful of police/authorities;
•    Be fearful of the trafficker, believing their lives or family members’ lives are at risk if they escape;
•    Exhibit signs of physical and psychological trauma e.g. anxiety, lack of memory of recent events, bruising, untreated conditions;
•    Be fearful of telling others about their situation;
•    Be unaware they have been trafficked and believe they are simply in a bad job;
•    Have limited freedom of movement;
•    Be unpaid or paid very little;
•    Have limited access to medical care;
•    Seem to be in debt to someone;
•    Have no passport or mention that someone else is holding their passport;
•    Be regularly moved to avoid detection;
•    Be controlled by use of witchcraft e.g. Ju Ju;

2.    Sexual Exploitation

Be aware, ordinary residential housing/hotels are being used more and more for brothels. People forced into sexual exploitation may:

•    Be moved between brothels, sometimes from city to city;
•    Sleeping on work premises;
•    Display a limited amount of clothing, of which a large proportion is sexual;
•    Display substance misuse;
•    Be forced, intimidated or coerced into providing sexual services;
•    Be subjected to abduction, assault or rape;
•    Be unable to travel freely e.g. picked up and dropped off at work location by another person;
•    Have money for their services provided collected by another person.

3.    Forced Labour

Where all the work is done under the menace of a penalty or the person has not offered themselves voluntarily and is now unable to leave. They may experience:

•    Threat or actual physical harm.
•    Restriction of movement or confinement.
•    Debt bondage i.e., working to pay off a debt or loan, often the victim is paid very little or nothing at all for their services because of deductions.
•    Withholding of wages or excessive wage reductions.
•    Withholding of documents e.g., passport/security card.
•    Threat of revealing to authorities an irregular immigration status.


•    Their employer is unable to produce the documents required.
•    Poor or non-existent health and safety standards.
•    Requirement to pay for tools and food.
•    Imposed place of accommodation (and deductions made for it).
•    Pay that is less than minimum wage.
•    Dependence on the employer for services.
•    No access to labour contracts.
•    Excessive work hours/few breaks.
4.    Child Abuse

The abuse of a child’s vulnerability by a person’s position of power or trust, exploiting that position to obtain sexual services in exchange for some form of favour for example alcohol, drugs, attention, or gifts. You may notice a child that is:

•    Often going missing/truanting.
•    Secretive.
•    Has unexplained money/presents.
•    Experimenting with drugs/alcohol.
•    Associating with/being groomed by older people (not in normal networks).
•    In relationships with significantly older people.
•    Taking part in social activities with no plausible explanation.
•    Seen entering or leaving vehicles with unknown adults.
•    Showing evidence of physical/sexual assault (including STDs).
•    Showing signs of low self-image/self-harm/eating disorder.

5.    Criminal Activities

The person is recruited and forced/deceived into conducting some form of criminal activity such as pickpocketing, begging, cannabis cultivation and benefit fraud. Same indicators as for forced labour but for cannabis cultivation you may also notice:
•    Windows of the property is permanently covered from the inside.
•    Visits to the property are at unusual times.
•    Property may be residential.
•    Unusual noises coming from the property e.g., machinery.
•    Pungent smells coming from the property.

6.    Domestic Servitude

A particularly serious form of denial of freedom; includes the obligation to provide certain services and the obligation to live on another person's property without the possibility of changing those circumstances. They may:

•    Be living and working for a family in a private home.
•    Not be eating with the rest of the family.
•    Have no bedroom or proper sleeping place.

•    Have no private space.
•    Be forced to work excessive hours; “on call” 24 hours a day.
•    Never leave the house without the ‘employer’.
•    Be malnourished.
•    Be reported as missing or accused of a crime by their ‘employer’ if they try to escape.


Any concerns of the above should be reported immediately to the designated Safeguarding Leads within CTS Training as detailed in the safeguarding policy, who will then take the appropriate action. 

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