In Toto Ed Ltd

Date created: 16/01/2026

Review date: 16/01/2027

1. Introduction

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps that In Toto Ed Group (“the Group”) has taken, and continues to take, to prevent modern slavery and human trafficking within its operations and supply chains. In Toto Ed Group operates specialist education provision, including Special Educational Needs (SEN) and Alternative Provision (AP) schools, supporting vulnerable children and young people. We recognise our responsibility to act ethically, transparently, and with integrity in all aspects of our work, and we are committed to safeguarding human rights.

2. Organisational Structure and Activities

In Toto Ed Group is an education provider operating within England. Our activities include the delivery of education and pastoral support, commissioning of professional services, procurement of educational resources, facilities management, catering, transport, and technology services. The Group’s workforce includes employed teaching staff, support staff, leadership teams, and a limited number of agency or contracted workers. We primarily operate within the UK, where the risk of modern slavery is considered lower; however, we remain vigilant, particularly in relation to third-party suppliers.

3. Policies and Governance

The Group has several policies and procedures in place that support our commitment to preventing modern slavery and human trafficking, including: 

• Safeguarding Policy
• Safer Recruitment Policy 
• Staff Handbook 
• Whistleblowing Policy
• Equality, Diversity and Inclusion Policy

These policies reinforce our expectations of ethical behaviour and compliance with the law and are reviewed regularly. 

4. Due Diligence Processes

In Toto Ed Group takes a proportionate, risk-based approach to due diligence. Our processes include: 

• Conducting right-to-work checks for all employees in line with UK legislation
• Using reputable recruitment and supply agencies
• Seeking assurances from suppliers that they comply with relevant employment, safeguarding, and labour laws
• Including modern slavery considerations within procurement and contract review where appropriate

Where concerns are identified, we commit to working with suppliers to address issues or, where necessary, terminating relationships.

5. Risk Assessment and Management

We recognise that potential risks of modern slavery may exist in certain supply chains, particularly those involving: 

• Agency staffing Facilities management and cleaning services 
• Catering and food supply chains
• IT hardware and educational materials sourced internationally

To mitigate these risks, we: 

• Limit the use of high-risk suppliers where possible
• Prioritise UK-based suppliers and regulated providers
• Maintain oversight through contract management and ongoing relationships

6. Effectiveness and Monitoring

The Group measures the effectiveness of its approach to tackling modern slavery through: 

• Regular review of safeguarding and HR processes
• Monitoring recruitment practices and staff feedback
• Encouraging reporting through whistleblowing and safeguarding channels

At present, no instances of modern slavery or human trafficking have been identified within the Group’s operations.

7. Training and Awareness

Staff receive safeguarding and safer recruitment training appropriate to their role. This training supports awareness of exploitation, vulnerability, and indicators of abuse, which aligns with our commitment to preventing modern slavery. Senior leaders involved in recruitment and procurement are made aware of modern slavery risks and responsibilities under the Modern Slavery Act.

8. Ongoing Commitment

In Toto Ed Group is committed to continuous improvement. Over the coming year, we aim to: 

• Further formalise supplier expectations regarding modern slavery
• Review procurement documentation to strengthen ethical standards
• Continue to embed awareness through safeguarding culture and leadership oversight

9. Approval

This statement has been approved by the Board of Directors of In Toto Ed Group and will be reviewed annually. 

Signed: Simon Gunton, Director
Date: 16/1/26