Modern Slavery and Ethical Purchasing Policy

1. Policy Statement & Scope

Classroom365 Limited is committed to preventing slavery, human trafficking, forced labour, child labour and exploitation in its operations, supply chain and products.

Although Classroom365 Limited is not currently required to publish a statutory Modern Slavery Statement under Section 54 of the Modern Slavery Act 2015, we maintain this policy voluntarily to support ethical purchasing, responsible supplier management, customer assurance and good governance. Section 54 applies to organisations carrying on business in the UK with an annual turnover above £36 million.

Classroom365 has zero tolerance towards slavery and human trafficking and expects its supply chain to comply with our values and ethical standards.

This policy applies to all procurement agreements, internal business operations, employees, contractors, suppliers and business partners involved in the delivery of Classroom365 services.

2. Organisational Structure & Internal Operations

Classroom365 operates in the UK education sector, providing managed ICT services, hardware and software to schools, academies and multi-academy trusts.

To ensure we conduct business ethically and transparently, we operate the following internal controls:

Recruitment and Selection: All successful applicants must provide proof of identity, proof of the right to work in the UK and, where relevant, evidence of professional qualifications.

Safeguarding: As an education-sector provider, school-facing staff are subject to appropriate safeguarding checks. This may include an Enhanced DBS check and, where the role is eligible and involves regulated activity, children’s barred list information. DBS guidance confirms that enhanced checks using children’s barred list information apply when someone is being assessed for a regulated activity involving children.

Classroom365 maintains a DBS log that is reviewed and updated in line with internal procedures and customer requirements.

Staff Training and Awareness: Relevant staff and contractors receive appropriate guidance on ethical conduct, anti-bribery standards and the signs of modern slavery. Staff are encouraged to report concerns confidentially to the Senior Management Team or a Director.

Training, guidance or policy acknowledgement records are retained as part of Classroom365’s ISO management system.

3. Supplier Ethical Standards – Ethical Purchasing

Suppliers are expected to uphold the following standards. Any serious or repeated violation may be deemed a material breach of contract and may result in supplier review, corrective action, suspension or termination of the supplier relationship.

3.1 Labour & Human Rights

Child Labour: Strictly forbidden. No person below the minimum legal age for employment shall be employed. Persons under 18 shall not be engaged in hazardous, unsafe or inappropriate work.

Forced Labour: We oppose all forms of forced, bonded, trafficked or compulsory labour. Employment must be voluntary. Suppliers shall not withhold identification documents, wages, deposits or personal property as a condition of employment.

Discrimination: All employment procedures must be fair and unbiased. Suppliers must support equal opportunity and must not discriminate unlawfully at any stage of employment.

Working Conditions: Suppliers must comply with applicable employment laws relating to pay, working time, rest breaks, holiday entitlement, employment status and safe working conditions.

3.2 Health, Safety & Environment

Health & Safety: Suppliers are responsible for ensuring a safe working environment in accordance with applicable laws, including conducting appropriate risk assessments and maintaining suitable emergency response arrangements.

Environment: Suppliers must comply with applicable environmental legislation, hold required permits where relevant, and manage waste, hazardous substances and product lifecycle impacts responsibly. Where relevant, suppliers should comply with applicable WEEE, product safety, environmental and hazardous substance requirements. This supports the principles set out in our wider Environmental & Net Zero Policy.

3.3 Business Ethics

Anti-Bribery & Corruption: Suppliers must maintain a zero-tolerance approach to bribery and corruption and ensure relevant staff and associates are aware of these principles.

Fraud & Money Laundering: Suppliers must maintain appropriate controls to prevent fraud, money laundering, tax evasion and other forms of financial crime.

Transparency: Suppliers are expected to provide accurate information when requested about their labour practices, modern slavery controls, subcontracting arrangements and supply chain risks.

4. Due Diligence and Risk Management

As part of our ISO management systems, Classroom365 identifies and monitors potential risks in its supply chain through:

Supplier Mapping: Regularly reviewing the supply chain to identify higher-risk suppliers, products, services or regions.

Evaluations: Evaluating modern slavery and ethical purchasing risks when onboarding or reviewing suppliers, particularly where suppliers provide ICT hardware, logistics, subcontracted labour, installation services or products involving global manufacturing.

Supplier Information: Requesting supplier policies, statements, certifications or compliance confirmations where appropriate.

Audits and Reviews: Classroom365 reserves the right to review supplier compliance through internal reviews, supplier questionnaires, external audits or joint evaluations where appropriate.

Escalation: Any concerns relating to modern slavery, human trafficking or unethical labour practices will be escalated to the Senior Management Team or a Director.

5. Effectiveness & Key Performance Indicators – KPIs

To measure the effectiveness of this policy, Classroom365 reviews the following areas as part of its ISO management system:

Supplier Engagement: Key and higher-risk suppliers are reviewed periodically using a risk-based approach. Where appropriate, Classroom365 may request information on modern slavery, ethical purchasing or supplier compliance.

Staff Training and Awareness: Relevant staff receive appropriate training, guidance or policy acknowledgement on identifying and escalating modern slavery risks. Records are retained where training or acknowledgement is completed.

High-Risk Supplier Review: Classroom365 aims to review high-risk suppliers annually or when there is a significant change in supplier activity, product type, supply chain risk or customer requirement.

Corrective Action: Supplier concerns, audit findings or non-conformities are recorded and managed through the appropriate corrective action or supplier review process.

Management Review: Modern slavery and ethical purchasing risks may be reviewed through management review, supplier review, risk register updates, internal audits or procurement decision-making.

6. Review and Approval

This policy is reviewed annually or sooner where there are significant changes to legislation, business operations, supplier risk, procurement arrangements, customer requirements or ISO management system requirements.

This policy has been reviewed and approved by the Board of Directors of Classroom365 Limited.

Document control
Version: 4.0
Last reviewed: May 2026
Next review due: May 2027
Approved by: Board of Directors
Policy owner: Classroom365 Limited