Modern Slavery Policy

Summary

Lakes First Aid is a small independent training organisation providing a range of first aid courses to individuals, groups & organisations. We offer training & qualifications that meet current Health & Safety requirements. We are members of Active Aid Ltd, a consortium of trainers who uphold our quality assurance and training standards within the first aid sector. We are also an approved training centre for the Qualifications Network (QNUK) recognised by Ofqual for delivering level 3 first aid training.

This policy relates to how we conduct our business in a fair & ethical way with respect to fundamental human rights and our commitment to the prevention of all forms of Modern Slavery. This policy applies to all persons working for us or on our behalf including the business owners, employees and our associate first aid trainers.

Modern Slavery is when an individual is exploited by others, for personal or commercial gain. This includes but is not limited to human trafficking, forced labour, debt bondage, descent–based slavery, child slavery, forced and early marriage, domestic servitude, sexual exploitation or criminal exploitation. Further details of these definitions can be found in Appendix 1.

Preventing Modern Slavery in our business

Lakes First Aid has a zero-tolerance approach to modern slavery and are fully committed to preventing modern slavery and human trafficking both in our business and in our supply chains.

We take seriously our responsibility for implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or with our suppliers. We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery consistent with our obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our associate staff, suppliers and other business partners and we expect that our suppliers will hold their own suppliers to the same high standards.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us. We expect our staff to avoid any activity that might lead to, or suggest, a breach of this policy.

We encourage our staff to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains. If staff believe or suspect a breach of this policy has occurred or that it may occur, they should notify either Ross Wallace or Sue Wallace as soon as possible.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

We take all reports of modern slavery extremely seriously and are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

Working with the appropriate organisations to improve standards
Removing that organisation from our preferred supplier list
Passing details to appropriate law enforcement bodies.

Risk management & review

We will monitor our risks and regularly review our performance in managing the prevention of modern slavery in our business. We consider the following factors as part of our risk management:

The risk a new associate trainer or supplier may have to our business
Whether an associate trainer or supplier has their own modern slavery policy
How well our policy has been enforced through checks within our business and our suppliers
The level of modern slavery training & awareness amongst our staff and associates

Further information on the topics and expected knowledge about modern slavery can be found in Appendix 2.

Additional policies

The following policies are recommended to be read in conjunction with this policy and are available on request:

Equality and Diversity Policy
Safeguarding Policy
Complaints Policy
Health & Safety Policy

This policy was approved by Ross Wallace on 1st February 2026

The policy is due for review on 1st February 2027

Appendix 1 – Definitions of modern slavery

Human trafficking

The use of violence, threats or coercion to transport, recruit or harbour 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. Victims may be forced to work long hours for little or no pay in poor conditions under verbal or physical threats of violence to them or their families.

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

A very old form of slavery, where people are where people are born into slavery, 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.

This involves a victim being forced to work in predominantly private households, usually performing domestic chores and childcare duties. Their freedom may be restricted and they may work long hours often for little or no pay, often sleeping where they work.

Sexual exploitation

This includes but is not limited to sexual exploitation and sexual abuse, forced prostitution and the abuse of children for the production of child abuse images/videos.

Criminal exploitation

This can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shop-lifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker.

References:

https://www.antislavery.org/slavery-today/modern-slavery/

https://www.walkfree.org/what-is-modern-slavery/

Appendix 2 – Key topics for the understanding and prevention of modern slavery

The basic principles of the Modern Slavery Act 2015

How our business can identify and prevent slavery and human trafficking

What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation

How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;

What external help is available, e.g. through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative

What steps the organisation should take if suppliers or contractors do not implement antislavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.