The policies, statements and procedures that keep our apprentices, employers and staff safe, treated fairly and properly informed. Every document below has been reviewed and re-approved for the 2026–27 apprenticeship funding year.
The policies that matter to apprentices, employers and the public, each owned by a named role, mapped to the law or guidance that requires it, and published here in full. Open any policy to read it; the reading window has a print option if you want to keep a copy.
Each policy carries its version, owner, approval and review dates. Policies marked “draft for ratification” are the 2026–27 editions awaiting board approval; details shown as “to confirm” are being completed before publication. Staff, delivery and governance policies beyond this suite are held in our internal policy library and available to inspectors, funders and partners on request.
How our policies are governed
Owned, approved, reviewed and open to challenge.
Good policies are only useful if they are current and if people can find them. This is the cycle every document on this page follows.
1
A named owner for every policy
Each policy is owned by a senior role, not a committee. The owner keeps it current, trains staff on it and reports on how it is working.
2
Board approval, aligned to the funding year
Policies are reviewed in June and July and approved by the board before 1 August, so they always reflect the funding rules that apply to new starts.
3
Version-controlled and published
Every document carries a version, approval date and next review date, listed in the library below. Full copies are available to any learner, employer or partner on request.
Raise a concern
Something you need to tell us?
Pick the route that fits. Every message reaches a named person, and you will always get a reply.
Safeguarding concern
Worried about an apprentice or learner? Speak to our Designated Safeguarding Lead straight away.
If someone is in immediate danger, call 999. The NSPCC helpline (0808 800 5000) and the Modern Slavery Helpline (08000 121 700) are available if you would rather speak to someone outside TLC.
SLW-01 · Safeguarding, Prevent & Learner Welfare
Safeguarding & Child Protection
Owner
Designated Safeguarding Lead
Status
Live
Version
v1.0 (draft for ratification)
Approved by
Managing Director / Board — safeguarding is a Board-level responsibility
Last reviewed
11 July 2026
Next review
11 July 2027 (reviewed at least annually, and after any serious incident)
Applies to All staff, associates, subcontractors, volunteers, trustees/directors and anyone acting on behalf of TLC
1Purpose and scope KCSIE 2024 · Children Act 2004 s.11
The Training & Learning Company ("TLC") is committed to safeguarding and promoting the welfare of every learner, and expects everyone connected with TLC to share that commitment. This policy sets out how we protect learners from harm, how we respond when we are worried about someone, and what each of us must do.
It applies to all staff, associates, subcontractors, volunteers, directors and anyone working on behalf of TLC, whoever they come into contact with. It covers all of our learners — including apprentices and learners aged 16 and 17, young people aged under 18, and adults, some of whom may be adults at risk. Where we work with learners under 18 or with adults at risk, the enhanced duties in this policy apply in full.
This is the overarching safeguarding policy. It works alongside our Prevent Duty policy (SLW-02), Safer Recruitment policy (SLW-04), Learner Health, Safety & Wellbeing policy (SLW-05) and Data Protection & UK GDPR policy (DPG-01).
2Legal and regulatory framework statutory guidance
We follow the safeguarding duties that apply to education and training providers, including in particular:
Keeping Children Safe in Education (statutory guidance, current edition) — where we train or recruit anyone under 18;
Working Together to Safeguard Children (2023);
the Children Act 1989 and 2004 (including the section 11 duty to safeguard and promote welfare);
the Care Act 2014, in respect of adults at risk of abuse or neglect;
the Counter-Terrorism and Security Act 2015 (the Prevent duty — see SLW-02);
the Sexual Offences Act 2003, and guidance on child sexual and criminal exploitation and county lines; and
the ESFA/DfE apprenticeship accountability and funding requirements on learner safeguarding and welfare.
3Definitions
Safeguarding means protecting learners from maltreatment, preventing harm to their health or development, ensuring they can learn safely, and taking action to enable all learners to have the best outcomes.
Abuse and neglect take many forms — physical, emotional, sexual, financial, neglect, domestic abuse, and specific risks such as child sexual exploitation (CSE), child criminal exploitation (CCE) and county lines, radicalisation, forced marriage, so-called honour-based abuse, female genital mutilation (FGM), bullying (including online), and self-neglect. An "adult at risk" is a person aged 18 or over who has care or support needs and is, or is at risk of, being abused or neglected and cannot protect themselves.
4Roles and responsibilities
Safeguarding is everyone’s responsibility. In particular:
The Board / Managing Director holds ultimate accountability for safeguarding, ensures this policy is resourced and reviewed, and receives regular safeguarding reports.
The Designated Safeguarding Lead (DSL) — to confirm — takes lead responsibility for safeguarding, is the first point of contact for concerns, makes and manages referrals, and holds the required enhanced training. The DSL can be reached on to confirm.
The Deputy DSL(s) — to confirm — act with the full authority of the DSL when the DSL is unavailable.
All staff must be alert to signs of harm, know how to raise a concern, respond appropriately, and complete safeguarding training. Safeguarding is never "someone else’s job".
5Our safeguarding culture and commitments
We create an environment where learners feel safe, are listened to, and know how to raise a concern. We recruit safely (SLW-04), we set clear expectations of professional conduct (Staff Code of Conduct, HR-06), and we take every concern seriously. We do not allow a fear of getting it wrong, or of damaging a relationship with an employer, to stop us acting in a learner’s interest.
6Recognising and responding to specific risks KCSIE 2024
Staff should be alert to the full range of safeguarding risks, including CSE and CCE and county lines, domestic abuse, mental ill-health and self-harm, radicalisation (respond via the Prevent duty, SLW-02), online harms, and — for learners in the workplace — risks arising in the employer’s setting. A learner may disclose directly, or you may simply notice that something is wrong. You do not need proof to raise a concern.
7If you are worried about a learner act the same day
The steps are simple and the same for everyone:
Respond calmly to any disclosure. Listen, do not promise confidentiality, and reassure the learner they were right to speak up.
Do not investigate, interview, or attempt to resolve it yourself, and do not contact the alleged perpetrator.
Make a written record of what you saw or were told, in the learner’s own words where possible, as soon as you can.
Report to the DSL (or Deputy) the same day using to confirm.
8Managing and referring concerns Working Together 2023
The DSL decides on the appropriate action, which may include a referral to children’s social care or adult social care, the police, or the multi-agency safeguarding hub. In to confirm, referrals are made to to confirm and, for adults at risk, to to confirm; the out-of-hours route is to confirm.
We share information promptly with the agencies who need it to keep a learner safe. Data-protection law does not prevent us sharing information for safeguarding purposes; where there is a risk of harm, safeguarding comes first. Information is shared on a need-to-know basis and recorded (see DPG-01).
9Allegations and concerns about staff KCSIE 2024 Part four
Where an allegation is made that a member of staff, associate or volunteer may have harmed a learner, behaved in a way that indicates they are unsuitable to work with them, or behaved in a way that raises concern, it is reported immediately to the Managing Director (or, if the allegation concerns the Managing Director, to to confirm). Allegations that meet the harm threshold are referred to the Local Authority Designated Officer (to confirm) within one working day. We also record and address lower-level concerns about conduct, so that we notice patterns early.
10Records and information sharing DPA 2018 · UK GDPR
Safeguarding records are made promptly, are factual and clear, and are stored securely and separately from general learner files, with access limited to those who need it. They are retained in line with our Data Retention & Records Management policy (DPG-02) and shared with other agencies where necessary to protect a learner, consistent with our Data Protection & UK GDPR policy (DPG-01).
11Safe recruitment and safeguarding in the workplace
We recruit and vet staff safely under our Safer Recruitment policy (SLW-04), including the appropriate level of DBS check for roles working with under-18s or adults at risk. Because many of our learners train in an employer’s workplace, we check that employers provide a safe environment, we agree how safeguarding concerns will be shared with us, and we make sure learners know how to contact the DSL directly, wherever they are training.
12Training and awareness
All staff receive safeguarding and Prevent training at induction and at least annually, and are kept up to date with briefings between times. The DSL and Deputies complete enhanced DSL training and refresh it at the required interval. Learners are told at induction what safeguarding means, who the DSL is, and how to raise a concern.
13Online safety
We promote safe use of technology by learners and staff, including on our learning platforms, and respond to online safety concerns — such as online bullying, exploitation or radicalisation — through this policy. Detailed provisions sit in our E-Safety & Learner Online Safety policy (SLW-09) and Information Security & Acceptable Use policy (DPG-03).
14Monitoring, review and breaches
The DSL monitors safeguarding activity and reports to the Board. This policy is reviewed at least annually, and immediately after any serious safeguarding incident or change in statutory guidance. A failure to follow this policy is treated seriously and may be a disciplinary matter. If you are ever unsure what to do, speak to the DSL — it is always right to ask.
Key safeguarding contacts
DSL
to confirm · to confirm
Deputy DSL
to confirm
Children’s services
to confirm
Adult social care
to confirm
Out of hours
to confirm
LADO
to confirm
Police
999 (emergency) · 101 (non-emergency)
SLW-01 · Safeguarding & Child Protection · The Training and Learning Company. Questions about this policy: enquiries@tlc-uk.org or 01792 700611.
SLW-02 · Safeguarding, Prevent & Learner Welfare
Prevent Duty
Owner
Designated Safeguarding Lead
Status
Under review
Version
v0.1 (draft for ratification)
Approved by
to confirm
Last reviewed
11 July 2026
Next review
11 July 2027 (reviewed at least annually, and sooner after any Prevent concern, serious incident, or change in the national threat level or statutory guidance)
Applies to All staff, associates, subcontractors, volunteers, trustees/directors and anyone acting on behalf of TLC, in respect of every learner and everyone they come into contact with
1Purpose and scope Counter-Terrorism and Security Act 2015, s.26
The Training & Learning Company ("TLC") has a legal duty, in exercising its functions, to have due regard to the need to prevent people from being drawn into terrorism. This is the Prevent duty. This policy explains what that means in practice, how we reduce the risk, and what each of us must do if we are worried that someone is being radicalised.
We treat Prevent as part of safeguarding, not as something separate or securitising. The aim is early, supportive help for a person who may be vulnerable — the same instinct that sits behind all of our safeguarding work.
This policy applies to all staff, associates, subcontractors, volunteers, directors and anyone working on behalf of TLC. It covers all of our learners — apprentices and learners aged 16 and 17, other young people under 18, and adults, some of whom may be adults at risk. It sits alongside our Safeguarding & Child Protection policy (SLW-01) and our Prevent Duty Risk Assessment (SLW-03), which records the specific risks in our settings and how we manage them.
2Legal and regulatory framework statutory duty and guidance
The main duties and guidance we follow are:
the Counter-Terrorism and Security Act 2015 — section 26 creates the Prevent duty, and sections 36 to 41 provide for Channel panels and support in England and Wales;
the statutory Prevent duty guidance for England and Wales (issued under section 29 of the Act, current edition), including the sector-specific guidance for the further education and training sector;
the Channel Duty Guidance (current edition), which governs how Channel referrals and panels work;
the Terrorism Act 2000 and the Terrorism Act 2006 (including the statutory definition of terrorism in the Terrorism Act 2000), and the Counter-Terrorism and Border Security Act 2019;
Keeping Children Safe in Education (statutory guidance, current edition) — where we train or recruit anyone under 18 — which treats radicalisation as a safeguarding risk;
the Equality Act 2010 and the Human Rights Act 1998, which we must respect when delivering the duty, including the rights to freedom of thought, expression and religion;
lawful freedom of speech, academic freedom and the expression of religious and political belief, which the Prevent duty guidance expects us to protect and to balance against the need to prevent people being drawn into terrorism;
UK GDPR and the Data Protection Act 2018, which govern how we share information about a Prevent concern (see section 13); and
the Department for Education (DfE) apprenticeship funding rules and accountability requirements, and Ofsted's current inspection framework, both of which expect providers to meet the Prevent duty and keep learners safe.
3Definitions
A few terms are used throughout, and it helps to be precise about them.
Terrorism — broadly, the use or threat of serious violence, or serious damage, designed to influence government or intimidate the public and made to advance a political, religious, racial or ideological cause (as defined in the Terrorism Act 2000).
Radicalisation — the process by which a person comes to support terrorism or extremist ideologies associated with terrorist groups.
Extremism — the government defines this in the Prevent guidance; in short, vocal or active opposition to fundamental values, or calls for the death of members of the armed forces. We use the current government definition rather than restating our own.
Channel — a voluntary, confidential, multi-agency programme that provides support to people identified as at risk of being drawn into terrorism. Consent is required (from the person, or a parent/guardian for under-18s) before support is provided.
Fundamental British values — democracy, the rule of law, individual liberty, and mutual respect and tolerance of those with different faiths and beliefs. We promote these through our teaching and culture.
4Roles and responsibilities
Prevent is everyone's responsibility, but some roles carry specific duties.
Who
What they are responsible for
Board / to confirm
Overall accountability for the Prevent duty; ensures the policy and risk assessment are resourced, reviewed and reported on; receives regular Prevent updates.
Designated Safeguarding Lead (DSL) — to confirm
Leads on Prevent as the day-to-day Prevent lead; is the first point of contact for concerns; decides on and manages referrals; maintains the risk assessment (SLW-03); holds the required Prevent and safeguarding training. Reachable on to confirm.
Deputy DSL(s) — to confirm
Act with the full authority of the DSL when the DSL is unavailable.
All staff, associates and subcontractors
Stay alert to signs that someone is being drawn into terrorism, know how to raise a concern, respond appropriately, and complete Prevent training. Never dismiss a worry or assume someone else will act.
Employers we work with
Kept aware of our expectations on learner welfare; supported to raise concerns to us about apprentices in the workplace (see section 9).
5Assessing and managing the risk SLW-03
We are required to assess where and how our learners might be at risk of being drawn into terrorism, and to act on what we find. Our Prevent Duty Risk Assessment (SLW-03) records the specific risks across our delivery — including the sectors and locations we work in, online delivery, and any local threats identified by to confirm — and the actions we take to reduce them.
We keep in contact with our regional or local Prevent coordinator and the to confirm, and we update the risk assessment at least annually and whenever something changes materially. This policy sets the framework; SLW-03 holds the detail.
6Recognising when someone may be at risk
There is no single sign of radicalisation, and most of the signs below are far more likely to have an innocent explanation. What matters is a change, a pattern, or a gut feeling that something is wrong. Possible indicators include:
becoming increasingly isolated from family, friends or peers, or from previous social groups;
a sudden change in behaviour, appearance, or friendships, or sympathy for extremist causes;
using scripted or divisive language, or expressing a fixed 'us and them' view of the world;
sharing, seeking or being drawn to extremist content, online or offline, or contact with people who promote it;
expressing a desire or intent to travel to areas of conflict, or to harm others to advance a cause; and
signs of grooming or exploitation — an older or online 'friend' who encourages secrecy, isolation, or hostility.
7If you are worried about someone act the same day
The steps are the same as for any safeguarding concern:
Respond calmly. Listen, do not promise confidentiality, and do not react in a way that shuts the person down.
Do not investigate, challenge the person's beliefs, or try to resolve it yourself, and do not tip off anyone who might make things worse.
Make a written record of what you saw or were told, in the person's own words where you can, as soon as possible.
Report it to the DSL (or Deputy DSL) the same day, using to confirm. If you cannot reach them and someone is in immediate danger, call 999.
For an immediate, credible threat to life, call 999. Non-emergency concerns can be reported to the police on 101 or via the confidential ACT anti-terrorist hotline on 0800 789 321.
8What happens next — assessment and Channel CTSA 2015, ss.36–41
When the DSL receives a Prevent concern, they will consider the information, gather any relevant context, and decide the right response. That might be internal pastoral support, a wider safeguarding response, contact with the to confirm, or — where the criteria are met — a referral into Channel.
Channel is voluntary and consent-based. It brings together the police, the local authority and other partners to assess vulnerability and, where appropriate, offer tailored support. A person (or, for an under-18, a parent or guardian) can decline Channel support. A referral is a request for an assessment, not an accusation, and being referred does not create a criminal record.
9Learners in the workplace and off-the-job apprenticeships
Many of our apprentices spend most of their time with an employer, and some learning happens online or off site. That does not reduce our duty. We make sure learners know how to raise a concern wherever they are, we tell employers what to do if they are worried about an apprentice, and we agree clear routes for an employer to contact the DSL. Where an employer's setting creates a specific risk, we record it in the risk assessment (SLW-03).
10Online safety and IT
A great deal of radicalisation happens online. On systems we control, we apply appropriate filtering and monitoring that is proportionate to the age and needs of our learners, and staff report anything of concern in the usual way. We help learners build the digital resilience to recognise and question extremist and manipulative content. This works alongside our E-Safety & Learner Online Safety policy (SLW-09) and our Information Security & Acceptable Use policy (DPG-03).
11Curriculum, British values and freedom of speech
The strongest protection is a confident, open learning environment. We build fundamental British values, critical thinking and respectful debate into teaching and learner support, so learners can weigh ideas, disagree well, and recognise when they are being manipulated.
We also protect lawful freedom of speech and the expression of religious and political belief. Prevent does not mean closing down difficult conversations — if anything it means creating a safe space to have them. Where the two duties appear to pull against each other, staff should speak to the DSL rather than resolve it alone.
12Visiting speakers, events and external partners SLW-10
External speakers, visitors and partners can add real value, but they must not become a route for extremist views to reach learners. All guest speakers and external visitors are approved in advance under our Guest Speaker & External Visitor Approval policy (SLW-10), with proportionate checks and, where needed, arrangements to challenge or balance contentious views.
13Information sharing and data protection UK GDPR · DPA 2018
We share information about a Prevent concern only with those who need it to keep someone safe — for example the DSL, the police, or the local Channel panel. Data protection law does not prevent this: safeguarding and the prevention of harm provide a lawful basis to share relevant, proportionate information, including where necessary without consent.
Prevent and Channel information is sensitive. We record and store it securely, keep it accurate, share only what is necessary, and retain it in line with our Data Retention & Records Management policy (DPG-02) — the specific retention period for Prevent records is to confirm. Our Data Protection & UK GDPR policy (DPG-01) sets out how personal data is handled generally.
14Training and awareness
Everyone needs enough knowledge to spot a concern and know what to do with it. All staff complete Prevent awareness training (for example the government's Prevent awareness e-learning, or to confirm) on induction and refresh it at least to confirm. The DSL and deputies hold enhanced Prevent and safeguarding training and keep it current. We also make sure learners know how to raise a concern and where to turn for help.
15Records
The DSL keeps a confidential record of Prevent concerns, decisions and any referrals, including the reasoning behind decisions and the outcome. These records support good decisions, continuity if a member of staff is unavailable, and our accountability to the DfE and Ofsted. They are held securely and separately from general learner files, and access is limited to those who need it.
16Monitoring, review and breaches
The DSL monitors how this policy works in practice — training completion, concerns raised, referrals and outcomes — and reports to the Board on Prevent risk. This policy and the risk assessment (SLW-03) are reviewed at least annually, and sooner after any incident, any change in the national threat level, or any change to the law or statutory guidance.
Failing to follow this policy — for example not passing on a concern — is treated seriously and may be dealt with under our disciplinary procedures. If you are ever unsure, stop and speak to the DSL. It is always better to check first.
SLW-02 · Prevent Duty · The Training and Learning Company. Questions about this policy: enquiries@tlc-uk.org or 01792 700611.
SLW-07 · Safeguarding, Prevent & Learner Welfare
Anti-Bullying & Harassment (Learners)
Owner
Head of Quality
Status
Draft for ratification
Version
v0.1 (draft for ratification)
Approved by
Managing Director / Board, on the recommendation of the Head of Quality
Last reviewed
to confirm
Next review
to confirm — reviewed at least annually, and after any serious incident
Applies to All learners and apprentices, and all staff, associates, subcontractors and volunteers who work with them; relevant to the employers who host our learners
1Purpose and scope Equality Act 2010 · Ofsted EIF
The Training & Learning Company ("TLC", "we") is committed to providing a learning environment where every learner is treated with dignity and respect and can train safely. This policy explains what bullying and harassment are, what we do to prevent them, and what happens when they are reported. It sets a clear standard: bullying and harassment of learners are never acceptable, whoever is involved and wherever they take place.
It applies to all our learners — including apprentices, learners aged 16 and 17, and adults — and to all staff, associates, subcontractors and volunteers who work with them. It covers behaviour between learners, behaviour by staff towards learners, and behaviour by learners towards staff. It applies on our premises, in the employer's workplace, at any TLC or off-site activity, on our online learning platforms, and online more generally where the behaviour affects a learner's safety or their learning.
This policy sits within our safeguarding framework. It works alongside our Safeguarding & Child Protection policy (SLW-01), our Learner Behaviour & Positive Attitudes policy (SLW-08), and our E-Safety & Learner Online Safety policy (SLW-09). Where staff are the ones affected, the relevant HR policies apply instead (see HR-07).
2Legal and regulatory framework statute & statutory guidance
This policy reflects the duties that apply to us as a training provider, including in particular:
the Equality Act 2010 — which defines harassment related to a protected characteristic, prohibits discrimination and victimisation, and (through the public sector equality duty, where it applies to functions we carry out) requires us to advance equality and foster good relations;
the Protection from Harassment Act 1997 — which makes a course of conduct amounting to harassment or stalking both a civil wrong and a criminal offence;
Keeping Children Safe in Education (statutory guidance, current edition) — where a learner is under 18, including its expectations on child-on-child abuse, sexual harassment and online abuse;
the Care Act 2014 — in respect of adults at risk of abuse or neglect, including psychological abuse;
the Online Safety Act 2023 — which created new offences of sending threatening or false communications and addresses online harms — together with the Communications Act 2003 and the Public Order Act 1986, relevant to threatening, abusive or harassing communications and stirring up hatred;
the Counter-Terrorism and Security Act 2015 (the Prevent duty) — where bullying or harassment overlaps with hateful extremism or targeting because of a belief (see SLW-02); and
the Ofsted Education Inspection Framework — under which inspectors consider learners' behaviour and attitudes, whether learners feel safe, and how well bullying, harassment and discrimination are dealt with.
3Definitions
It helps to be precise about what we mean. The words below have specific meanings in this policy.
Bullying is behaviour, usually repeated over time, that intentionally hurts, intimidates, excludes or undermines someone, where there is a real or perceived imbalance of power. It can be physical, verbal, or indirect (such as spreading rumours or deliberately leaving someone out).
Harassment, in the Equality Act sense, is unwanted conduct related to a protected characteristic that has the purpose or effect of violating someone's dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. It does not have to be repeated, and it does not have to be aimed at the person to affect them.
The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.
Sexual harassment is unwanted conduct of a sexual nature, or less favourable treatment because someone rejected or submitted to such conduct. It includes sexual comments, jokes, messages, images, touching and pressure.
Victimisation is treating someone badly because they have complained about bullying or harassment, or supported someone else's complaint. It is prohibited in its own right.
Cyberbullying / online harassment is any of the above carried out through phones, messaging, social media or online platforms.
A hate incident is any incident that the victim, or anyone else, perceives to be motivated by hostility or prejudice based on a protected characteristic.
4What it can look like examples, not an exhaustive list
Bullying and harassment take many forms. The table below gives examples to help you recognise them — it is not a complete list, and behaviour can be a mix of several types.
Type
Examples
Physical
Hitting, pushing, or unwanted physical contact; damaging or hiding belongings; threatening gestures.
Verbal
Name-calling, mocking, insults, threats, spreading rumours, or repeated 'jokes' at someone's expense.
Discriminatory
Comments or conduct targeting a person's race, disability, sex, religion or belief, sexual orientation, gender reassignment, age, or other protected characteristic.
Sexual
Sexual comments, jokes or messages; sharing or requesting sexual images; unwanted touching; sexual pressure or coercion.
Online
Abusive or threatening messages, group chats set up to exclude or humiliate, posting private images, impersonation, or 'pile-ons'.
Indirect / social
Deliberately excluding someone, turning others against them, or humiliating them in front of the group.
5Our commitment
We create a culture in which bullying and harassment are unlikely to take root and are challenged when they occur. We talk openly with learners about respect, difference and healthy relationships at induction and through the programme; we model respectful behaviour ourselves; and we make it easy and safe to report a concern. We treat every report seriously, we do not tolerate retaliation against anyone who raises one, and we are honest that we cannot promise a particular outcome — only a fair, prompt and confidential response.
6Roles and responsibilities
Keeping learners safe from bullying and harassment is a shared responsibility. In particular:
The Head of Quality — to confirm — owns this policy, monitors reports and trends, and ensures the policy is followed and reviewed.
The Designated Safeguarding Lead (DSL) — to confirm — leads on any case that is, or may be, a safeguarding matter (including sexual harassment, and anything involving a learner under 18 or an adult at risk).
All staff, associates and subcontractors must model respectful behaviour, be alert to bullying and harassment, respond to and record what they see or are told, and never ignore or minimise it.
Learners are expected to treat others with respect and to report concerns (see section 8).
Employers who host our learners are asked to maintain a respectful workplace, to deal with concerns arising in their setting, and to tell us promptly when a concern involves one of our learners.
7What we expect of you
If you are a learner, we expect you to treat everyone you meet through your programme — other learners, staff, and people in your workplace — with respect, in person and online. That means not bullying, harassing or excluding others, not sharing content that is abusive or humiliating, and speaking up if you see it happening to someone else. Getting this right is part of the personal and professional behaviour your apprenticeship is helping you build.
You will not get into trouble for reporting a genuine concern in good faith, even if it turns out to be mistaken. Deliberately making a false report to harm someone, however, is itself a form of harassment and will be treated as such.
8How to report a concern you have options
You do not have to be certain, and you do not have to sort it out yourself. Tell us in whichever way feels safest:
speak to any member of TLC staff you trust — your tutor, assessor or coach — who will pass it on;
contact the Designated Safeguarding Lead directly on to confirm;
use to confirm to report it, including anonymously if you prefer;
if you are an employer, tell your usual TLC contact or the DSL as soon as you become aware of a concern.
We know reporting can feel hard, especially when the behaviour comes from someone with power over you, or someone in your workplace. We will listen, take you seriously, and agree with you what happens next. Anonymous reports may limit what we can do, but we will still act on them as far as we can.
9How we respond fair, prompt, proportionate
When a concern is reported, we act quickly and proportionately. In outline:
we record what has been reported, factually and in the learner's own words where possible;
we make sure the learner affected is safe and supported, and we consider any immediate steps needed to prevent further harm;
we decide who should handle it — the DSL where it is or may be a safeguarding matter, otherwise the Head of Quality or a nominated manager;
we look into what happened fairly, hearing from those involved, keeping the parties apart where appropriate, and keeping the person who reported it informed of progress;
we take reasonable action to stop the behaviour and prevent it recurring — which may range from a facilitated conversation and clear expectations, through the learner behaviour process (SLW-08), to referral to the employer, an awarding organisation, or the police; and
we check back afterwards to make sure the behaviour has stopped and there has been no retaliation.
10Links to safeguarding and Prevent KCSIE · Care Act 2014
Bullying and harassment are frequently safeguarding matters. Any report that involves a learner under 18 or an adult at risk, anything of a sexual nature, and anything indicating a risk of significant harm is handled through our Safeguarding & Child Protection policy (SLW-01) and, where relevant, referred to external agencies. Where behaviour is linked to hateful or extremist views, or a learner is being targeted because of a belief, we also consider the Prevent duty (SLW-02). When in doubt, we treat a concern as a safeguarding matter and involve the DSL.
11Support for those involved
We support the learner who has been affected — practically and emotionally — and can signpost pastoral, wellbeing and external support (see our Mental Health & Wellbeing policy, SLW-06). We also treat a learner accused of bullying or harassment fairly: they are told what is alleged, given a chance to respond, and supported to change their behaviour, because for many of our younger learners this is part of learning how to work with others. Support is offered regardless of the eventual outcome.
12Records and information UK GDPR · DPA 2018
We keep a clear, factual record of every report and of the action we take, so that we can respond consistently and notice patterns — for example repeated behaviour by or towards the same person, or hotspots in a particular setting. Records are held securely, shared only with those who need them, and retained in line with our Data Retention & Records Management policy (DPG-02) and our Data Protection & UK GDPR policy (DPG-01). Where a matter is a safeguarding concern, the safeguarding recording arrangements in SLW-01 apply.
13Training and awareness
Staff receive training on recognising and responding to bullying and harassment as part of safeguarding training at induction and at least annually, including on sexual harassment and online abuse. Learners are made aware of this policy at induction — what bullying and harassment are, that they will not be tolerated, and how to report — and the message is reinforced through the programme and our wider personal development offer.
14Monitoring, review and breaches
The Head of Quality monitors reports and outcomes and reports on them to the leadership team, so that we can spot trends and improve. This policy is reviewed at least annually, and sooner if the law, statutory guidance or our own experience shows it needs to change. Bullying or harassment by a member of staff is a serious matter and may lead to disciplinary action; by a learner, it is dealt with through the learner behaviour process (SLW-08) and, where serious, may affect their place on the programme. If you are ever unsure whether something counts, ask — it is always right to raise it.
SLW-07 · Anti-Bullying & Harassment (Learners) · The Training and Learning Company. Questions about this policy: enquiries@tlc-uk.org or 01792 700611.
GOV-07 · Governance, Risk & Business
Health & Safety
Owner
Operations Manager
Status
Under review
Version
v0.1 (draft for ratification)
Approved by
Managing Director, on behalf of the Board — health and safety is a Board-level responsibility
Last reviewed
11 July 2026
Next review
11 July 2027 (or sooner after any serious incident or change in the law)
Applies to All staff, associates, subcontractors, agency workers, volunteers and visitors; and learners while on TLC premises or taking part in TLC-run activity
1Purpose and scope HSWA 1974 s.2(3)
The Training & Learning Company ("TLC", "we") is committed to providing a safe and healthy environment for everyone affected by what we do. This policy is our written statement of general health and safety policy, as required of any employer with five or more staff. It sets out our commitment, who is responsible for what, and the arrangements we have in place to manage health and safety.
It applies to all staff, associates, subcontractors, agency workers, volunteers and visitors, and to learners while they are on TLC premises or taking part in an activity we run. Many of our learners train in an employer's workplace, where the employer holds the primary duty for their safety — this policy explains how we work with employers to keep those learners safe too.
This is the overarching health and safety policy. It works alongside our Lone Worker policy (HR-18), Business Continuity policy (GOV-06), Learner Health, Safety & Wellbeing policy (SLW-05) and Risk Management policy (GOV-05).
2Legal and regulatory framework statute & regulations
We manage health and safety in line with our duties under UK legislation, including in particular:
the Health and Safety at Work etc. Act 1974 — our primary duty to protect employees, and others affected by our work, so far as is reasonably practicable;
the Management of Health and Safety at Work Regulations 1999 — including the duty to assess risks, to appoint competent persons, and to make specific assessments for young persons and for new or expectant mothers;
the Workplace (Health, Safety and Welfare) Regulations 1992;
the Regulatory Reform (Fire Safety) Order 2005;
the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR);
the Health and Safety (Display Screen Equipment) Regulations 1992, the Manual Handling Operations Regulations 1992, the Control of Substances Hazardous to Health Regulations 2002 (COSHH), the Provision and Use of Work Equipment Regulations 1998 (PUWER), and the Personal Protective Equipment at Work Regulations 1992 (as amended in 2022 to cover workers as well as employees), as relevant to our activities;
the Health and Safety (First-Aid) Regulations 1981 and the Health and Safety (Consultation with Employees) Regulations 1996;
the Employers' Liability (Compulsory Insurance) Act 1969; and
the Corporate Manslaughter and Corporate Homicide Act 2007.
On the employment side, we recognise that raising a genuine health and safety concern is a protected act: staff are protected from detriment and from dismissal for doing so under sections 44 and 100 of the Employment Rights Act 1996, and we make reasonable adjustments for disabled staff and learners under the Equality Act 2010. Health and safety concerns can also be raised through our Whistleblowing policy (HR-05).
3Definitions
A few terms used throughout:
Reasonably practicable — the balance the law requires between the level of a risk and the time, trouble and cost of controlling it. It does not mean "whatever is convenient".
Hazard — anything with the potential to cause harm. Risk — the likelihood that it will, and how serious the harm could be.
Risk assessment — the process of spotting hazards, deciding who might be harmed and how, and putting sensible controls in place.
Competent person — someone with the training, knowledge and experience to help us meet our health and safety duties.
4Roles and responsibilities HSWA 1974 s.2 & s.7
Health and safety works only if everyone knows their part.
Who
What they are responsible for
Board / Managing Director
Overall accountability; setting the policy, resourcing it, and reviewing performance.
Operations Manager (policy owner)
Day-to-day management of health and safety, keeping this policy and the risk assessments current, and reporting to the Board. Contact: to confirm.
Managers and team leaders
Making sure risk assessments are followed in their area, that their people are trained, and that concerns are acted on.
All staff, associates and volunteers
Taking reasonable care of their own and others' safety, following procedures, using equipment properly, and reporting hazards, incidents and near misses.
Competent person / adviser
to confirm — provides specialist advice.
Under section 7 of the 1974 Act, every worker has a personal legal duty to take reasonable care and to co-operate with us on health and safety. Interfering with or misusing anything provided for safety is a serious matter.
5Our health and safety commitments
We commit to provide safe premises, equipment and systems of work; to assess and control risks; to give staff and learners the information, instruction, training and supervision they need; to consult our people on matters affecting their safety; and to keep this policy and our arrangements under review. We hold employers' liability insurance as required by law, and the current certificate is displayed and available to staff.
We would always rather someone stopped and asked than pressed on with something that felt unsafe. No deadline, and no relationship with an employer, is worth someone getting hurt.
6Risk assessment Management Regs 1999 reg.3
We assess the risks arising from our activities and premises, record the significant findings, and put proportionate controls in place. Risk assessments are reviewed regularly, and whenever something changes — a new activity, new equipment, an incident, or a person with particular needs. Staff must follow the controls set out in the assessment for any task they carry out.
7Learners training in an employer's workplace HSWA 1974 s.3
When a learner trains on an employer's premises, that employer holds the primary duty for their health and safety — but we do not simply hand the learner over. Before placing a learner we satisfy ourselves that the employer provides a safe environment, has appropriate insurance and risk assessments, and knows how to raise a safety concern with us. We check this at onboarding and keep it under review through our visits.
If we become aware that a learner is unsafe in a workplace, we act — raising it with the employer, adjusting or pausing the placement, and, where a learner may be at risk of harm, following our Safeguarding policy (SLW-01). Learners are told, at induction, how to reach TLC directly if they are worried about their safety, wherever they are training.
8Accidents, incidents, near misses and RIDDOR RIDDOR 2013
All accidents, incidents, near misses and work-related ill health must be reported and recorded, however minor they seem — near misses tell us where the next accident might happen. Report using to confirm and tell the Operations Manager. We record the details in the accident book, keeping any personal data secure and in line with our Data Protection & UK GDPR policy (DPG-01).
9Fire safety and emergencies RRFSO 2005
We carry out a fire risk assessment for our premises and keep it up to date. Escape routes are kept clear, fire equipment is maintained, alarms are tested, and evacuation drills are held. The responsible person for fire safety is to confirm, and fire marshals are to confirm. Everyone must know the escape routes and assembly point for wherever they are working, and follow the evacuation procedure the moment the alarm sounds — never stopping to collect belongings.
10First aid First-Aid Regs 1981
We provide first aid appropriate to our premises and activities. Our trained first aiders are to confirm, and first aid kits are located at to confirm. First aiders record the help they give. If you are unwell or injured at work, tell someone — do not struggle on alone.
11Managing specific risks DSE · COSHH · PUWER · PPE
Because most of our work is training and office-based, our main day-to-day risks are display screen equipment, manual handling, slips and trips, lone and remote working, driving for work, and work-related stress. We manage each of these proportionately:
Display screen equipment — we provide workstation assessments and encourage regular breaks; free eye tests are available where DSE use requires them.
Manual handling — we avoid unnecessary lifting and provide guidance and equipment where it is needed.
Hazardous substances — any cleaning or other substances that fall under COSHH are assessed and stored safely.
Work equipment and electrical safety — equipment is maintained and portable appliances are checked at a sensible interval; do not use anything that looks damaged.
Lone and remote working — managed under our Lone Worker policy (HR-18).
Wellbeing and work-related stress — treated as a health and safety matter, not a weakness; talk to your manager or use the support routes in our wellbeing arrangements.
12Consultation, information and equipment HSCER 1996
We consult staff on health and safety matters that affect them, welcome concerns and suggestions, and act on them. The health and safety law poster, our insurance certificate and this policy are available to everyone. Where any personal protective equipment is needed for a task, we provide it free of charge to staff and workers alike, and it must be used as instructed.
13Records and information
We keep the records the law and good practice require — risk assessments, the accident book, RIDDOR reports, fire and equipment checks, and training records. These are stored securely and kept for the periods set out in our Data Retention & Records Management policy (DPG-02); any personal data in them is handled under our Data Protection & UK GDPR policy (DPG-01).
14Training and information for staff and learners
Everyone receives health and safety information at induction — including how to report an incident, where the fire exits and first aiders are, and who the Operations Manager is. Staff receive further training appropriate to their role, and those with specific responsibilities (first aiders, fire marshals, the competent person) hold the relevant certificated training and keep it up to date. Learners are given the health and safety information they need for TLC activity as part of their induction.
15Monitoring, review and breaches
The Operations Manager monitors health and safety — through inspections, incident trends and staff feedback — and reports to the Board. This policy is reviewed at least annually, and immediately after any serious incident or change in the law. Deliberately ignoring health and safety rules, or putting others at risk, is a serious matter and may be treated as a disciplinary issue. If you are ever unsure whether something is safe, stop and ask — that is always the right call.
GOV-07 · Health & Safety · The Training and Learning Company. Questions about this policy: enquiries@tlc-uk.org or 01792 700611.
GOV-01 · Governance, Risk & Business
Complaints & Appeals (Learner / Employer)
Owner
Managing Director
Status
Draft for ratification
Version
v0.1 (draft for ratification)
Approved by
Managing Director, on behalf of the Board
Last reviewed
to confirm
Next review
to confirm (reviewed at least annually, or sooner if our procedures or the funding rules change)
Applies to All staff, associates, subcontractors and volunteers, and available to all learners, apprentices and employers who deal with TLC
1Purpose and scope Ofsted framework · funding rules
This policy explains how The Training & Learning Company ("TLC", "we") handles complaints and appeals from our learners, apprentices and the employers we work with. It sets out how to raise a concern, what happens next, how long each step should take, and how to take a matter further if you are still not satisfied.
It applies to all staff, associates, subcontractors and volunteers, who must follow it, and it is available to every learner, apprentice and employer, who may use it. It covers complaints about any part of our service — teaching and support, the conduct of our people, the way we have handled information, or how we have run a programme.
Some matters have their own dedicated route, and this policy points you to it rather than duplicating it. Complaints about assessment decisions or examination results are handled under our Assessment Appeals & Enquiries about Results policy (AO-04). Concerns about malpractice or maladministration in assessment go through AO-02. Staff who want to raise a wrongdoing concern in confidence use our Whistleblowing policy (HR-05).
2Legal and regulatory framework regulatory
This policy reflects the standards expected of an apprenticeship and training provider, including in particular:
the Department for Education (DfE) apprenticeship funding rules and provider agreement, which require us to operate a clear complaints procedure and to tell learners and employers how to escalate to the DfE if they remain dissatisfied;
the Ofsted inspection framework, under which inspectors consider how well leaders and managers listen and respond to the views of learners and employers;
the Equality Act 2010, which means our complaints process must be accessible and must not disadvantage anyone because of a protected characteristic, with reasonable adjustments made where needed;
the UK GDPR and the Data Protection Act 2018, which govern how we handle the personal data in a complaint file (see DPG-01); and
the Consumer Rights Act 2015, where an adult learner has bought training directly from us as a paying customer.
3Definitions
We use a few terms in a specific way:
A complaint is an expression of dissatisfaction about our service, our staff, or how something was handled, where you want a response and, usually, something put right.
An appeal is a request to have a decision we have made looked at again — for example a decision to remove a learner from a programme. (Appeals about assessment or grades go through AO-04.)
A concern is a lower-level niggle that can often be sorted out on the spot, without becoming a formal complaint.
Working day means Monday to Friday, excluding public holidays and any period TLC is closed.
4Roles and responsibilities
Handling complaints well is a shared job. In particular:
The Managing Director owns this policy, is accountable for how complaints are handled, hears formal-stage complaints or appoints a senior colleague to do so, and reports on complaints to the Board.
The Complaints Coordinator — to confirm — logs complaints, acknowledges them, tracks timescales, and makes sure each one reaches the right person.
Managers and staff try to resolve concerns early and fairly, respond honestly, and never take a complaint personally or discourage someone from raising one.
Everyone treats the person complaining with respect and keeps the details confidential, sharing them only with those who need to know.
5Our principles
We aim to make complaining easy and safe. We take every complaint seriously, deal with it promptly and fairly, and keep the person informed. We are honest when we have got something wrong, we say sorry when an apology is due, and we explain our reasons when we cannot give someone the outcome they wanted. We never disadvantage a learner, apprentice or employer for having complained in good faith.
6How to raise a complaint three stages
You do not need to use any special form or particular words. You can raise a complaint in person, by phone, by email or in writing, and we will help you put it in writing if that is easier. If you need the process in a different format, more time, or support to take part, tell us and we will make reasonable adjustments.
We work in three stages, and most complaints are settled early:
Stage 1 — Informal. Raise it with the person you normally deal with, or their manager. Many things can be sorted out quickly with a conversation, and we would always rather fix a problem than log a file.
Stage 2 — Formal. If the informal route does not resolve it, or the matter is serious, ask for it to be dealt with formally. Contact to confirm. We will acknowledge it, investigate, and give you a written response.
Stage 3 — Review. If you are still not satisfied, you can ask the Managing Director (or a senior colleague not previously involved) to review how the complaint was handled and the outcome reached.
7Timescales working days
We aim to deal with complaints as quickly as we sensibly can. Our target timescales are set out below. If we cannot meet a target — for example because a matter is complex or a key person is away — we will tell you, explain why, and give you a new date.
Step
What happens
Our target
Acknowledge
We confirm we have received your formal complaint and tell you who is handling it
to confirm
Investigate & respond
We look into it and give you a written response and outcome
to confirm
Request a review
You tell us you want the Stage 3 review
to confirm
Review outcome
The Managing Director (or senior reviewer) responds
to confirm
8Appeals against a decision
If we have made a decision that affects you — for example withdrawing you from a programme, or turning down a request — and you think it is wrong or unfair, you can appeal. Set out what decision you are appealing and why, and send it to to confirm within to confirm of being told. A senior person who was not involved in the original decision will consider your appeal and give you a written outcome. Appeals about assessment marks, grades or results are not dealt with here — use the Assessment Appeals & Enquiries about Results policy (AO-04).
9If you are still not satisfied: taking it further external routes
We would always like to put things right ourselves, and the routes above give us the chance to. But if you have been through our process and are still unhappy, you can take the matter outside TLC. The right body depends on what the complaint is about:
If your complaint is about…
Where you can take it
Your apprenticeship or the training we deliver (once our process is exhausted)
The Department for Education (DfE) apprenticeship complaints procedure — to confirm
The overall quality of our provision
Ofsted, which can consider concerns raised about a provider — to confirm
A qualification, assessment or grading matter
The relevant awarding organisation or end-point assessment organisation, and ultimately Ofqual — see AO-04 / AO-02
How we have handled personal data
The Information Commissioner's Office (ICO) — see DPG-01
We will tell you which external route applies to your complaint and give you the up-to-date contact details when we send our final response. Going to an external body does not cost you anything and will not affect how we treat you.
10Anonymous, repeated and unreasonable complaints
We would rather you gave your name, because it lets us keep you updated and look into things properly — but we will still consider an anonymous complaint on its merits where we can. In the rare case where someone pursues a complaint in a way that is abusive, or keeps raising the same matter after it has been fully answered, we may limit how we deal with it. We will always explain our reasons in writing, and this never applies simply because a complaint is persistent or hard to hear.
11Records and information UK GDPR · DPA 2018
We keep a central log of formal complaints and appeals, recording what was raised, what we did, the outcome and any actions taken. Complaint files contain personal data and are handled under our Data Protection & UK GDPR policy (DPG-01): they are stored securely, seen only by those who need to, and kept in line with our Data Retention & Records Management policy (DPG-02). We do not keep complaint records mixed in with a learner's general or assessment file.
12Learning from complaints
A complaint is free feedback about where our service falls short, and we treat it that way. The Managing Director reviews complaints and appeals for patterns and themes, feeds what we learn into our quality improvement work (QUA-04), and reports to the Board. Where a complaint shows something needs to change, we change it — and, where we can, we tell the person who raised it what difference they made.
13Training and awareness
Staff are briefed on this policy at induction and reminded of it periodically, so that everyone knows how to receive a complaint well and where to send it. Learners and employers are told about this policy at the start of their programme or engagement, and the current version is available on request and at to confirm.
14Monitoring, review and breaches
The Managing Director monitors how well we meet our own standards, including whether we hit our timescales, and reports to the Board. This policy is reviewed at least once a year, and sooner if the funding rules or our procedures change. Not following this policy — for example discouraging someone from complaining, or sitting on a complaint — is taken seriously and may be a disciplinary matter. If you are ever unsure how to handle a complaint, ask the Complaints Coordinator or the Managing Director.
GOV-01 · Complaints & Appeals (Learner / Employer) · The Training and Learning Company. Questions about this policy: enquiries@tlc-uk.org or 01792 700611.
HR-05 · Employment & HR
Whistleblowing
Owner
Managing Director
Status
Draft for ratification
Version
v0.1 (draft for ratification)
Approved by
to confirm
Last reviewed
to confirm
Next review
to confirm
Applies to All workers of TLC — employees, associates, agency workers, volunteers, trainees, and staff of subcontractors delivering on TLC's behalf
1Purpose and scope PIDA 1998 · ERA 1996 Pt IVA
The Training & Learning Company ("TLC", "we") wants people to feel able to speak up when they see something seriously wrong at work — wrongdoing, danger, or dishonesty — without fear of being punished for it. This policy explains what whistleblowing is, how to raise a concern, what we will do about it, and how the law protects you when you do.
It applies to all our workers in the widest sense: employees, associates, agency and contract staff, volunteers, trainees, and staff of subcontractors delivering on our behalf. It covers concerns about TLC, its people, its funding, or its delivery — including matters that arise in an employer's workplace where our apprentices train.
This is not the route for a personal complaint about your own treatment at work — that is a grievance (HR-04) — nor for a learner or employer complaint (GOV-01). Section 4 explains the difference. Concerns about fraud or misuse of public funding also engage our Fraud & Financial Irregularity policy (GOV-03).
2Legal and regulatory framework statute
Whistleblowing is protected by law. This policy is built on:
the Public Interest Disclosure Act 1998 (PIDA), which inserted the whistleblowing protections into the Employment Rights Act 1996 (Part IVA, sections 43A onwards);
the Employment Rights Act 1996, which gives a worker the right not to be subjected to a detriment (s.47B), and an employee the right not to be dismissed (s.103A), for making a protected disclosure;
the Enterprise and Regulatory Reform Act 2013, which added the requirement that a disclosure be, in the worker's reasonable belief, in the public interest — and which means good faith is no longer a condition of protection, though a lack of it can reduce any compensation;
the Public Interest Disclosure (Prescribed Persons) Order 2014 (as amended), which lists the regulators a worker may disclose to externally (see section 8);
the Equality Act 2010, under which victimising someone for raising or supporting a discrimination complaint may separately be unlawful; and
our obligations to the Department for Education (which administers apprenticeship funding), and to Ofsted and awarding bodies, to report fraud, financial irregularity and serious concerns about delivery.
3Definitions
A protected disclosure is a "qualifying disclosure" made in the right way. It qualifies where you reasonably believe it is in the public interest and that it shows one or more of the following, whether happening now, in the past, or likely in future:
a criminal offence (for example fraud, theft or bribery);
a failure to comply with a legal obligation;
a miscarriage of justice;
a danger to the health or safety of any person;
damage to the environment; or
the deliberate concealment of any of the above.
A "worker" for these purposes is defined broadly and goes wider than employees — it includes agency workers, some contractors and trainees. You do not have to be right for a disclosure to be protected: the test is whether you held the belief reasonably and in the public interest. A concern that turns out to be mistaken is still protected, provided your belief was reasonable when you raised it.
4Whistleblowing or grievance? What this policy is not
Whistleblowing is about a wrong that affects others or the public — not about how you personally have been treated. If your concern is really about your own employment (pay, workload, a dispute with a colleague or manager), that is a grievance and should go through the Grievance policy (HR-04), which is designed to resolve it properly.
Use whistleblowing (HR-05) for…
Use another route for…
Fraud, theft or misuse of funding
A dispute about your own pay or hours → Grievance (HR-04)
Falsifying learner or ILR data
A learner or employer complaint → Complaints (GOV-01)
A serious health & safety danger
A safeguarding concern about a learner → Safeguarding (SLW-01)
Bribery, or covering up any of the above
Bullying or harassment you have experienced → Grievance (HR-04)
5Our commitment to you
If you raise a genuine concern under this policy, TLC will:
take it seriously and look into it fairly;
protect you from any detriment, victimisation or dismissal for having spoken up;
keep your identity confidential as far as we reasonably can, if that is what you want;
tell you how your concern will be handled and, as far as we properly can, what came of it; and
not think less of you for raising it — even if it turns out there was nothing wrong.
We would always rather you spoke up and were wrong than stayed quiet and were right. Silence is how small problems become serious ones.
6Roles and responsibilities
The Board / Managing Director owns whistleblowing at the top level, is accountable for this policy, and ensures concerns are acted on independently and without reprisal.
The Whistleblowing Officer — to confirm — is the main point of contact for concerns, oversees how they are handled, and reports to the Board. They can be reached at to confirm.
The Chair / Board contact — to confirm — receives disclosures that concern the Managing Director, or where the usual routes would not be appropriate.
All managers must support anyone who raises a concern, must never penalise or allow others to penalise them, and must pass concerns on promptly.
All workers should raise genuine concerns and cooperate honestly with any enquiry.
7How to raise a concern internal disclosure
In most cases the quickest way to get something put right is to raise it inside TLC. You can raise a concern:
with your line manager, if you feel able to;
with the Whistleblowing Officer, to confirm, at to confirm; or
directly with the Managing Director, or — if your concern is about the Managing Director — with to confirm.
You can raise it in whatever way suits you — in person, by phone, or in writing. Give as much detail as you can: what you are worried about, why, and any dates, names or documents. You are not expected to prove anything or to investigate it yourself. If you would find it helpful, you may bring a colleague or trade union representative to any meeting about your concern.
8Raising a concern outside TLC Prescribed Persons Order 2014
We hope you will feel able to raise concerns with us first, because that is usually how they get fixed fastest. But the law also lets you disclose to a "prescribed person" — an independent regulator — and you remain protected when you do, provided you reasonably believe the matter falls within that regulator's remit and that the information, and any allegation in it, is substantially true. Depending on the concern, the relevant body may include:
Concern
Prescribed person / regulator
Standards of education and training
Ofsted
Misuse of apprenticeship or public funding
Secretary of State for Education / Department for Education
Tax fraud
HM Revenue & Customs
Data protection breaches
Information Commissioner's Office (ICO)
Health and safety dangers
Health and Safety Executive (HSE) or the local authority
For serious wrongdoing you may also seek independent advice — for example from the charity Protect (the whistleblowing advice line), a solicitor, or your trade union — before deciding what to do. We would encourage you to take advice rather than to go straight to the media, as wider public disclosures are only protected by the law in limited circumstances.
9Confidentiality and anonymous concerns
If you ask us to, we will do our best to keep your identity confidential and not reveal it without your consent. We cannot promise absolute confidentiality — occasionally your identity may have to be disclosed, for example if the matter becomes a legal proceeding — but if that looks likely we will talk to you first.
You can raise a concern anonymously, and we will still consider it. Be aware, though, that anonymity makes it harder to look into a concern properly, to ask you follow-up questions, or to protect and update you. A named concern is almost always easier to act on.
10How we handle a concern
When you raise a concern, we will acknowledge it promptly and decide how it should be looked into. Depending on what it is, that may mean an internal enquiry, an independent investigation, or referral to a regulator, the police or an auditor. We will handle it proportionately and as quickly as the matter allows.
We will keep you informed of how your concern is being dealt with and, as far as we are properly able, of the outcome. Sometimes we will not be able to tell you everything — for example where doing so would breach someone else's confidentiality or prejudice an investigation — but we will explain that. Where a concern turns out to be well founded, we will put things right and take any action needed to prevent it happening again.
11Protection from reprisal ERA 1996 s.47B & s.103A
The law gives you real protection. A worker who makes a protected disclosure has the right not to be subjected to any detriment because of it, and an employee dismissed for making a protected disclosure is treated as automatically unfairly dismissed. "Detriment" is wide — it covers things like being sidelined, denied opportunities, disciplined, threatened, or treated worse in any way because you spoke up. The protection also covers detriment inflicted by your colleagues or agents in the course of their work, for which TLC can itself be held responsible.
TLC will not tolerate anyone victimising, harassing or retaliating against a person who has raised a genuine concern, or who has supported someone else in doing so. If you believe you are being treated badly because you blew the whistle, tell the Whistleblowing Officer or Managing Director at once. We will treat retaliation as a serious disciplinary matter, up to and including dismissal.
12Untrue or malicious disclosures
You are protected when you raise a concern that you reasonably believe to be true, even if it later proves to be mistaken — you will never be penalised for an honest concern that turns out to be wrong. However, if someone knowingly makes a false allegation, or raises a concern maliciously or for personal gain, that falls outside these protections and may itself be treated as a disciplinary matter.
13Records and information UK GDPR · DPA 2018
We keep a confidential record of concerns raised, how they were handled and what was decided, so that we can learn from them and evidence that we took them seriously. These records are held securely, with access limited to those who need it, and are processed in line with our Data Protection & UK GDPR policy (DPG-01). They are retained for to confirm and then securely destroyed, in line with our Data Retention & Records Management policy (DPG-02).
14Training, monitoring, review and breaches
Workers are made aware of this policy at induction and reminded of it periodically, and those handling concerns receive appropriate guidance. The Whistleblowing Officer reports to the Board on the concerns raised and how they were resolved, so that the Board can satisfy itself the policy is working and being used. This policy is reviewed at least annually, and sooner if the law or our arrangements change materially. A failure to follow it — including any act of reprisal against a whistleblower — will be dealt with under our Disciplinary policy (HR-03).
HR-05 · Whistleblowing · The Training and Learning Company. Questions about this policy: enquiries@tlc-uk.org or 01792 700611.
DPG-01 · Data Protection & Information Governance
Data Protection & UK GDPR
Owner
Data Protection Lead
Status
Live
Version
v1.0
Approved by
Managing Director, on behalf of the Board
Last reviewed
11 July 2026
Next review
11 July 2027 (or on material change in law or processing)
Applies to All staff, associates, subcontractors and volunteers processing personal data on behalf of TLC
1Purpose and scope UK GDPR Art. 5
This policy sets out how The Training & Learning Company ("TLC", "we") protects the personal data it holds, and what every member of staff must do to keep that data safe. It applies to all personal data we process — on paper or electronically — about learners, apprentices, employers, job applicants, employees, associates and subcontractors, wherever that data is held.
It applies to all staff, associates, agency workers, volunteers and subcontractors who process personal data on our behalf. Compliance is a condition of engagement with TLC. Breaching it may be treated as a disciplinary matter and, in serious cases, may amount to a criminal offence.
2The law we follow DPA 2018 · PECR 2003
We process personal data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Where we send marketing or use cookies and similar technologies, we also follow the Privacy and Electronic Communications Regulations 2003 (PECR). The Information Commissioner’s Office (ICO) is our supervisory authority, and TLC is registered with the ICO as a data controller.
As an apprenticeship training provider we also process personal data to meet obligations to the Department for Education and the funding agency, to awarding organisations and end-point assessment organisations, and under the apprenticeship funding rules. Those obligations sit alongside — not instead of — our data-protection duties.
3The principles we work to UK GDPR Art. 5(1)
Everyone at TLC must handle personal data in line with the seven data-protection principles. Personal data must be:
processed lawfully, fairly and in a transparent way;
collected only for specified, explicit and legitimate purposes, and not used in a way incompatible with those purposes;
adequate, relevant and limited to what is necessary (data minimisation);
accurate and, where necessary, kept up to date;
kept in a form that identifies people for no longer than is necessary (storage limitation);
kept secure, including protection against unauthorised processing, loss, destruction or damage (integrity and confidentiality); and
handled by TLC in a way we can demonstrate and evidence (accountability).
4Our lawful bases for processing UK GDPR Art. 6 & 9
We only process personal data where we have a lawful basis under Article 6 of the UK GDPR. In practice TLC relies on:
Activity
Usual lawful basis
Delivering an apprenticeship or training programme
Contract, and/or legitimate interests
Reporting learner data to the funding agency / DfE (e.g. the ILR)
Legal obligation
Safeguarding and Prevent duties
Legal obligation / vital interests / public task
Employing and managing staff
Contract and legal obligation
Optional marketing and alumni updates
Consent
Keeping our premises and systems secure
Legitimate interests
Where we process special category data — such as health information, disability, ethnicity or data used for equality monitoring — we identify an additional condition under Article 9 (and, where relevant, a condition in Schedule 1 of the Data Protection Act 2018) before we begin. We record the basis and any condition in our Record of Processing Activities.
5Roles and responsibilities
Everyone has a part to play. In particular:
The Board / Managing Director owns data protection at the top level and is accountable for it.
The Data Protection Lead advises on compliance, maintains our records, handles individual-rights requests and breaches, and is the ICO contact point. (TLC is not currently required to appoint a statutory Data Protection Officer; if that changes, we will.)
Managers make sure their teams follow this policy and that new processing is checked before it starts.
All staff must complete data-protection training, follow this policy, and report any concern or breach immediately.
6What we collect and why
We collect only the personal data we need. For learners and apprentices this typically includes contact and identity details, unique learner number, prior attainment, eligibility and right-to-work evidence, learning and progress records, assessment and achievement data, and — where relevant — health, learning-support and equality information. For employers we hold business contacts and agreement details. For staff we hold the information needed to employ and pay them.
We tell people what we do with their data through clear privacy notices at the point we collect it. Privacy notices are written in plain English and explain the purposes, lawful bases, who we share data with, how long we keep it, and how to exercise their rights.
7Sharing personal data UK GDPR Art. 28
We share personal data only where there is a lawful basis and, usually, a written agreement in place. As an apprenticeship provider we routinely share learner data with the Department for Education and the funding agency (including through the Individualised Learner Record and the apprenticeship service), with awarding organisations and end-point assessment organisations, and with the employer of an apprentice as needed to deliver and confirm the programme.
Where another organisation processes personal data on our behalf — for example an IT or MIS supplier, or a subcontractor — we put a written data-processing agreement in place under Article 28, carry out due diligence, and make sure they give sufficient guarantees over security. We do not appoint a processor who cannot meet those guarantees.
8Individual rights UK GDPR Art. 12–22
People have rights over their personal data, and we respect them. These include the right to be informed; to access their data (a subject access request); to have inaccurate data corrected; to erasure; to restrict or object to processing; to data portability; and rights in relation to automated decision-making.
Some rights are qualified: for example, we may not be able to erase data we are legally required to keep for funding or audit purposes. Where a right does not apply, we explain that to the person clearly.
9Keeping data secure UK GDPR Art. 32
We protect personal data with appropriate technical and organisational measures. These include access controls and strong authentication, encryption of devices and of data in transit where appropriate, secure disposal of paper and equipment, role-based access on a need-to-know basis, regular backups, and staff training. Personal data must not be stored on personal devices or unauthorised cloud accounts, and must not be emailed unencrypted where it is sensitive.
Staff must lock screens when away from them, use strong and unique passwords, be alert to phishing, and never share login credentials. If in doubt about whether something is secure, ask before you send.
10Personal data breaches UK GDPR Art. 33–34
A personal data breach is any security incident that leads to personal data being lost, stolen, destroyed, altered, or disclosed to, or accessed by, someone who should not have it. A lost laptop, a mis-sent email, a mislaid file and a ransomware attack are all breaches.
We keep a record of every breach — including those we decide not to report — with the facts, the effects and the action taken.
11Data protection by design, and DPIAs UK GDPR Art. 25 & 35
We build data protection into new projects, systems and ways of working from the start, rather than bolting it on afterwards. Before we start any processing that is likely to result in a high risk to individuals — for example a new system holding sensitive data, or large-scale monitoring — we carry out a Data Protection Impact Assessment (DPIA) with the Data Protection Lead. If you are planning something new that involves personal data, talk to the Data Protection Lead before you commit to it.
12How long we keep data UK GDPR Art. 5(1)(e)
We keep personal data only as long as we need it, then dispose of it securely. Retention periods are set out in our Data Retention & Records Management policy (DPG-02). Learner and funding records are kept for the periods required by the apprenticeship funding rules and audit requirements; employment records follow statutory and business-need periods. When a retention period ends, data is deleted or anonymised.
13International transfers UK GDPR Ch. V
We keep personal data in the UK wherever possible. If personal data is transferred outside the UK — for example through a cloud service — we make sure an appropriate safeguard is in place, such as adequacy regulations or the ICO’s International Data Transfer Agreement, and we record it. Staff must not move personal data outside approved systems.
14Training, monitoring and review
All staff complete data-protection training on induction and refresh it at least annually. TLC monitors compliance with this policy, and the Data Protection Lead reports to the Board on data-protection risk. This policy is reviewed at least once a year, and sooner if the law or our processing changes materially.
If you are ever unsure how to handle personal data, stop and ask the Data Protection Lead. It is always better to check first.
to confirm (reviewed at least annually, and on any material change in law or guidance)
Applies to All staff, associates, agency workers, volunteers, directors and subcontractors acting for TLC — and, in the parts about learning and services, our learners, apprentices and employer partners
1Purpose and scope Equality Act 2010
This policy sets out how The Training & Learning Company ("TLC", "we") promotes equality, values diversity and builds an inclusive place to work and learn. It explains what we will not tolerate, what you can expect from us, and what each of us must do. It includes our Equality & Diversity Charter — the short set of promises we hold ourselves to.
It applies to every part of what we do: recruiting, employing and developing staff; recruiting, teaching and assessing learners and apprentices; working with employers, awarding organisations, end-point assessment organisations and subcontractors; and how we design and deliver our training. It applies to all staff, associates, agency workers, volunteers, directors and subcontractors. Following it is a condition of working with, or on behalf of, TLC.
We are honest about the limits of a policy: writing this down does not, on its own, make us inclusive. It sets the standard. The behaviour that meets it is on all of us, every day.
2The law and frameworks we follow Equality Act 2010 · Ofsted inspection framework
The Equality Act 2010 is the main law behind this policy. It protects people from discrimination, harassment and victimisation because of a "protected characteristic". We also work to:
the Employment Rights Act 1996 and wider UK employment law, in how we treat staff;
the Worker Protection (Amendment of Equality Act 2010) Act 2023, and our duty to take reasonable steps to prevent the sexual harassment of staff (see also HR-07);
the Human Rights Act 1998, which protects rights such as respect for private and family life and freedom of thought, conscience and belief;
the Ofsted inspection framework for further education and skills, which expects providers to promote equality of opportunity, tackle discrimination and prepare learners for life in modern Britain;
the DfE apprenticeship funding rules, which require us to give fair and equal access to our provision and to support learners who need it.
3What the words mean Equality Act 2010, Pt 2
A few terms used throughout this policy have a specific legal meaning. It helps to know them.
Protected characteristics — the nine grounds the law protects (listed in the next section).
Direct discrimination — treating someone worse than others because of a protected characteristic.
Indirect discrimination — a rule or practice that applies to everyone but puts people with a characteristic at a disadvantage, and cannot be objectively justified.
Harassment — unwanted conduct related to a characteristic that violates someone's dignity, or creates an intimidating, hostile, degrading, humiliating or offensive environment.
Victimisation — treating someone badly because they have raised, or supported, a complaint about discrimination.
Reasonable adjustments — the changes we make so a disabled person is not put at a substantial disadvantage.
The Equality Act protects nine characteristics. Discrimination, harassment or victimisation because of any of them is unlawful, and against everything we stand for.
Protected characteristic
What it covers, in plain terms
Age
How old you are, or the age group you are seen to belong to.
Disability
A physical or mental impairment with a substantial, long-term effect on day-to-day activities.
Gender reassignment
Proposing to undergo, undergoing or having undergone a process to change gender.
Marriage and civil partnership
Being married or in a civil partnership.
Pregnancy and maternity
Being pregnant, and the period after giving birth, including breastfeeding.
Race
Colour, nationality, and ethnic or national origins.
Religion or belief
A religion, or a philosophical belief — including having none.
Sex
Being a man or a woman.
Sexual orientation
Whether you are attracted to your own sex, the opposite sex, or both.
5Our Equality & Diversity Charter
This is the short version — the promises we make to everyone who works with or learns with TLC.
We treat you fairly and with respect, whoever you are.
We recruit, promote, teach and assess on merit — never on assumptions about a person or a group.
We make reasonable adjustments so disability, health or circumstance is not a barrier to taking part.
We take bullying, harassment and discrimination seriously, and we act on them.
We welcome you telling us when we get it wrong, and we will not punish you for speaking up.
We build equality and inclusion into what we teach, not just how we behave.
We ask the same of you in return: treat colleagues, learners and employers with respect, challenge unfairness when you see it, and tell someone if something is wrong.
6Roles and responsibilities
Everyone is responsible for their own conduct and for helping to make TLC inclusive. Some people hold specific responsibilities:
The Board and Managing Director own equality and inclusion at the top of TLC and hold us to account for it.
The Head of Quality owns this policy, keeps it up to date, oversees equality monitoring and reports on it.
Managers set the tone in their teams, model fair behaviour, respond to concerns promptly, and make sure adjustments happen.
The HR Manager supports fair recruitment, employment and casework, and handles complaints under the relevant HR procedures.
All staff, associates and subcontractors follow this policy, complete their training, and treat everyone with respect.
Employers we work with are expected to provide a workplace free from discrimination and harassment for our apprentices.
7Equality in employment
We aim for a workforce where people can do their best work and be themselves. We recruit and select on merit against the requirements of the role, following our Recruitment & Selection policy (HR-01), and we apply the same fairness to pay, promotion, development, flexible working, leave and the end of employment.
We do not tolerate discrimination against, or harassment of, staff because of a protected characteristic. Where a job applicant or employee is disabled, we make reasonable adjustments — to the recruitment process, the role or the workplace — so they are not put at a substantial disadvantage.
8Equality for learners, apprentices and employers
Fair and equal access runs through our provision. We do not discriminate in who we recruit onto programmes, how we teach and assess, or the support we offer. We make our recruitment, information and initial assessment accessible, and we consider each learner's starting point and needs.
We make reasonable adjustments and, where they apply, arrange access arrangements for assessment through the relevant awarding organisation or EPAO (to confirm), so a disability or learning difficulty does not unfairly affect a learner's result. We work with employers so apprentices train in a workplace that is safe, respectful and free from discrimination, and we act if we learn that it is not.
We also build equality, diversity and inclusion into what learners study — including fundamental British values and preparing learners for life and work in a diverse society — as Ofsted's inspection framework expects.
9Bullying, harassment and victimisation Worker Protection Act 2023
Bullying, harassment and victimisation are not tolerated at TLC — between colleagues, towards learners, or between learners. This includes sexual harassment, and harassment related to any protected characteristic, whether in person, in writing, online or on social media.
You will not be treated badly, and your position will not suffer, because you have raised a genuine concern about discrimination or harassment, or supported someone else who has. Victimising someone for doing so is itself a disciplinary matter.
10Raising a concern
If you experience or witness discrimination, harassment or unfair treatment, please tell us — we can only put right what we know about.
Staff can raise it informally with a manager or HR, or formally under the Grievance policy (HR-04) or the anti-harassment procedure (HR-07).
Learners and apprentices can raise it with their tutor or assessor, or through our learner complaints route (to confirm).
Employers and other partners can raise a concern with their TLC contact or at to confirm.
We take every concern seriously, deal with it confidentially so far as we can, and aim to resolve it fairly and without delay. Serious matters may be dealt with under our disciplinary procedure, and some conduct may be unlawful.
11Equality monitoring and data Equality Act 2010 · UK GDPR · DPA 2018
We collect and review equality data — on our workforce and our learners — so we can see who is, and is not, getting a fair chance, and act on what we find. Giving this information is voluntary, and we explain why we ask.
Data about protected characteristics is special category personal data. We handle it lawfully and securely under our Data Protection & UK GDPR policy (DPG-01), use it in a way that does not identify individuals wherever possible, and keep it only as long as we need it. We report on equality data to to confirm at least to confirm.
12Training and awareness
All staff complete equality, diversity and inclusion training at induction and refresh it at least annually, with extra training for managers on fair recruitment, adjustments and handling concerns. We make sure learners understand equality, respect and fundamental British values as part of their programme. We keep records of training completed.
13Monitoring, review and breaches
The Head of Quality monitors how this policy works in practice — through equality data, complaints, feedback and quality reviews — and reports to the Board. We review the policy at least once a year, and sooner if the law, guidance or our provision changes materially.
A failure to follow this policy is treated seriously. For staff it may be a disciplinary matter and, in serious cases, may amount to unlawful discrimination or harassment for which TLC and the individual can be held liable. If you are ever unsure, ask — it is always better to check first.
HR-02 · Equality, Diversity & Inclusion (incl. E&D Charter) · The Training and Learning Company. Questions about this policy: enquiries@tlc-uk.org or 01792 700611.
GOV-12 · Governance, Risk & Business
Anti-Slavery & Human Trafficking
Owner
Managing Director
Status
Draft for ratification
Version
v0.1 (draft for ratification)
Approved by
to confirm
Last reviewed
11 July 2026
Next review
July 2027
Applies to All TLC staff (employed, agency and volunteer), directors, contractors, and suppliers acting on TLC's behalf. Sections on reporting and safeguarding also concern learners and employers.
1Purpose and scope
Modern slavery is a crime and a grave abuse of human rights. It takes many forms - slavery, servitude, forced or compulsory labour, and human trafficking - and it can be hidden in plain sight, including in training, recruitment and the supply chains that sit behind them.
This policy sets out our commitment to preventing modern slavery and human trafficking, what we expect of you, and what to do if you have a concern. We are a small organisation, so we are honest about our reach: we cannot inspect every link in every supply chain. What we can do is act on what we see, ask the right questions of the people we work with, and never look away.
It applies across everything TLC does - delivering apprenticeships and skills training, working with employers and learners, purchasing goods and services, and recruiting our own people.
Who is covered - all staff, directors, agency workers, volunteers, contractors and anyone acting for TLC.
What is covered - our own operations, our recruitment, our procurement, and the employers and partners we place learners with.
What is not covered - this policy does not replace our safeguarding response; where a learner or child is at risk, follow the safeguarding policy alongside this one.
2Policy statement
TLC has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity, and to putting in place reasonable steps to make sure slavery and trafficking are not taking place in our business or our supply chains.
We treat everyone who works for or with us fairly and lawfully.
We expect the same standards from our suppliers, employers and partners.
We support anyone who raises a genuine concern, and no one will be penalised for doing so.
We will report suspected modern slavery to the appropriate authorities.
3Legal and regulatory framework Modern Slavery Act 2015
This policy reflects our obligations under UK law and the standards expected of a DfE-funded training provider. The key instruments are:
Modern Slavery Act 2015 - the principal statute, creating the offences of slavery, servitude, forced or compulsory labour, and human trafficking, and (for larger organisations) the transparency in supply chains duty at section 54.
Human Rights Act 1998 and Article 4 of the European Convention on Human Rights - the prohibition of slavery and forced labour.
Employment Rights Act 1996 and the National Minimum Wage Act 1998 - fair pay and lawful working conditions.
Equality Act 2010 - protection from discrimination and harassment.
Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003 - including the rule that a work-seeker must not be charged a fee to find or keep work.
Immigration, Asylum and Nationality Act 2006 and Immigration Act 2016 - right-to-work checks and the labour market enforcement framework.
Gangmasters (Licensing) Act 2004 and the remit of the Gangmasters and Labour Abuse Authority.
Health and Safety at Work etc. Act 1974 - safe and healthy working conditions.
UK GDPR and the Data Protection Act 2018 - lawful handling of any personal data gathered when acting on a concern.
The DfE apprenticeship funding rules and the safeguarding expectations that apply to us as a training provider.
4Definitions
Term
What it means
Slavery
Treating a person as if you own them, and controlling their life.
Servitude
Forcing someone to provide services, with no realistic way for them to leave.
Forced or compulsory labour
Making someone work under threat of a penalty, where they have not offered themselves freely.
Human trafficking
Arranging or facilitating the travel of another person with a view to their exploitation.
Exploitation
Includes sexual exploitation, forced labour, domestic servitude, criminal exploitation (for example forced offending) and the removal of organs.
Debt bondage
Forcing someone to work to pay off a debt they can never realistically clear.
5Roles and responsibilities
Tackling modern slavery is everyone's job, but some people carry specific responsibilities.
Who
Responsibility
to confirm
Overall accountability for this policy, for our anti-slavery approach, and (where required) for the annual statement.
to confirm
Approving the policy, overseeing due diligence, and ensuring resources are in place.
to confirm
First point of contact where a learner, apprentice or child may be a victim; links this policy to the safeguarding response.
to confirm
Right-to-work checks, fair recruitment, and handling concerns about our own workforce.
to confirm
Supplier due diligence and contract terms.
All staff
Staying alert, following this policy, and reporting concerns promptly.
6Recognising the signs
You do not need to be certain. If something feels wrong, that is enough to report it. Possible indicators include:
A person seems fearful, withdrawn, or is rarely allowed to speak for themselves.
Someone else holds their identity documents, bank cards or wages.
Signs of physical or psychological abuse, or a person who looks malnourished or unkempt.
A learner or worker is unsure of their own address, or is picked up and dropped off at unusual hours.
Wages that are unusually low, paid to someone else, or subject to unexplained deductions.
A single address, phone number or bank account linked to several different people.
Reluctance to engage with authorities, or a rehearsed, inconsistent account of their situation.
7Raising and reporting a concern
If you suspect modern slavery or trafficking, act the same day.
If someone is in immediate danger, call 999.
Otherwise, report to the to confirm or, in their absence, to to confirm without delay.
Record what you saw, heard and when, using to confirm. Stick to facts.
Where a learner or child may be a victim, the safeguarding policy is followed alongside this one.
Potential victims can be referred into the National Referral Mechanism (NRM), the UK framework for identifying and supporting victims. TLC will confirm whether it is a designated 'first responder' organisation and, if not, will work with an organisation that is. to confirm.
You can also raise concerns under our whistleblowing arrangements. Concerns raised in good faith are protected, and you will not suffer any detriment for speaking up - even if you turn out to be mistaken.
8Our own workforce and recruitment
We reduce the risk of exploitation in our own hiring by:
Carrying out right-to-work checks on everyone we employ, before they start.
Never charging a worker a fee to obtain or keep work.
Paying at least the National Minimum Wage / National Living Wage and paying wages directly to the worker's own account.
Providing clear written terms of employment and lawful working hours.
Being alert where several applicants share an address, phone number or bank account.
9Supply chains, employers and due diligence
As a training provider we place learners with employers and buy in goods and services. Both carry risk, and both deserve reasonable scrutiny.
We expect suppliers, subcontractors and delivery partners to comply with this policy and with the Modern Slavery Act 2015.
We include anti-slavery expectations in contracts and, where proportionate, in our supplier onboarding checks.
When placing learners, we make reasonable checks that the employer offers safe, lawful working conditions - this links to our safeguarding and health and safety arrangements.
Higher-risk sectors and any use of labour providers receive closer attention, including checks that any labour provider is licensed by the Gangmasters and Labour Abuse Authority where the law requires it.
We reserve the right to end a relationship with any supplier or employer that will not meet these standards.
10Learners, apprentices and safeguarding
Many of our learners are young or otherwise vulnerable, which can make them targets. Modern slavery, criminal exploitation and trafficking sit within our wider safeguarding and Prevent duties.
Concerns about a learner aged under 18, or any learner at risk, are handled through the safeguarding policy as well as this one.
Staff working with learners receive safeguarding training that includes exploitation awareness.
We consider exploitation risk as part of learner support, particularly at enrolment and on work placements.
11Risk assessment
We keep a proportionate view of where our exposure is greatest and focus our effort there. Risk is reviewed at least annually and considers our sectors, our suppliers, our use of any labour providers, and the profile of our learners and placements. to confirm.
12Records and information
When we act on a concern we may handle sensitive personal data. We do so lawfully under the UK GDPR and the Data Protection Act 2018.
We record only what is necessary, keep it secure, and share it only with those who need it or with the authorities.
Records are retained in line with our data retention schedule. to confirm.
Data sharing with police, the NRM or other agencies is handled under the appropriate lawful basis, including where necessary the safeguarding and 'substantial public interest' conditions.
13Training and awareness
Staff cannot act on what they do not recognise. So:
All staff receive awareness of modern slavery indicators and this reporting route as part of induction.
Staff in higher-exposure roles - recruitment, procurement, learner support - receive additional guidance.
Training is refreshed to confirm and after any significant incident or legal change.
14Monitoring, review and breaches
The policy owner monitors how well this policy is working, including any concerns raised and how they were handled. The policy is reviewed at least annually, or sooner if the law or our operations change.
Breaches of this policy by staff will be dealt with under our disciplinary procedure and may amount to gross misconduct.
Breaches by suppliers or partners may lead to contracts being ended.
Suspected criminal conduct will be reported to the police and relevant authorities.
Related policies
to confirm
Safeguarding & Prevent Policy
to confirm
Whistleblowing Policy
to confirm
Recruitment & Selection Policy
to confirm
Data Protection & Privacy Policy
to confirm
Procurement & Supplier Management Policy
to confirm
Health & Safety Policy
to confirm
Equality, Diversity & Inclusion Policy
GOV-12 · Anti-Slavery & Human Trafficking · The Training and Learning Company. Questions about this policy: enquiries@tlc-uk.org or 01792 700611.
