This statement covers the financial year ending 31 August 2025.
1. Introduction and Statement from Leadership
Nord Anglia Education (‘NAE’) is committed to preventing modern slavery, human trafficking and labour exploitation across our operations and supply chain.
This statement is published pursuant to Section 54 of the UK Modern Slavery Act 2015, following the updated UK Government guidance issued in March 2025, which encourages clearer disclosures, practical evidence of action and continuous improvement.
2. Our Organisation, Structure and Supply Chains
NAE is currently a family of more than 80 premium international schools, based in more than 30 countries around the world. We offer personalised, inspiring learning to more than 100,000 students between the ages of 2 and 18 years old. We have approximately 22,000 employees, most of whom are based in our schools. Our staff are largely directly employed and are not in any category which is generally seen to be vulnerable to modern slavery, so our focus is to ensure that there are policies and procedures in place for our contractors and suppliers.
With some exceptions, our procurement activities are mostly carried out by our schools to ensure they reflect local needs, and do not involve large or complex supply chains. This means that individual schools are usually responsible for undertaking due diligence, evaluation, analysis and monitoring of procurement activities in the first instance, and will have close working relationships with the relevant suppliers. However, there is considerable oversight of these activities from our specialist regional and central teams, particularly in relation to higher risk areas.
Our key supply chain categories are as follows:
- Catering and food services
- School transport services (e.g., buses)
- General maintenance & facilities management
- Office supplies and educational materials
- School uniform supply
- Information Technology
- Marketing, recruitment and professional services
- Venues and events
Given the nature of our operations, most goods and services we procure are low risk from a modern slavery perspective. However, the production of school uniforms — which may involve textile manufacturing in higher-risk countries — has been identified as our most significant risk area. We have also identified cleaning and catering as
medium risk areas. This is consistent with government guidance emphasising supply-chain risk mapping and being transparent around potential areas of risk.
We are committed to deepening visibility within these supply chains, as encouraged by the updated government guidance.
3. Policies on Modern Slavery
We have policies in place to mitigate the risk of modern slavery both in our operations and supply chain.
These include:
- Code of Conduct and Ethics: we recognise that an ethical culture is a fundamental requirement for a successful, sustainable business and are committed to upholding the highest ethical standards in everything we do.
- Modern Slavery Policy: we have a zero-tolerance approach to modern slavery. This includes ensuring that there is transparency throughout our business and in our approach to tackling modern slavery.
- Whistleblowing Protection Policy: Our staff and suppliers are encouraged to speak-up. We have a global whistleblowing hotline to enable this to happen anonymously if preferred and clear policies in respect of non-retaliation. These principles sit at the heart of our ethical compliance programme.
- Procurement Policy: This applies to all to schools and entities within NAE. It stresses the importance of ensuring that our procurement activities meet all legal and ethical requirements, and that appropriate due diligence is carried out before appointing suppliers.
- Child Protection & Safeguarding Policies: The welfare of our students is paramount. We have a duty to keep them safe and promote their well-being. We have developed a comprehensive safeguarding and governance framework that is reviewed regularly to ensure it continues to reflect best practice. This includes conducting background checks on staff and third parties who visit our schools, as well as mandatory training requirements.
The updated UK Government guidance stresses the importance of ensuring that policies have been implemented effectively. We will continue to ensure that these standards are embedded across all our schools and functional teams – see section 7 for further details.
4. Risk Management
NAE has an Enterprise Risk Management [‘ERM’] framework. Risks are identified, mitigated and reviewed according to an annual cycle and the ERM framework is based on the principle that the NAE Board is focussed on those risks capable of undermining the strategy or long-term viability of NAE, while other risks are managed at appropriate levels within the organisation. The Group Risk Officer has overall responsibility for this process. The Group Risk Officer is supported by a central risk and compliance team and has a reporting line to the Chair of the Audit and Risk Committee.
Modern slavery related risks have been integrated into our ERM programme and are considered as part of our risk management processes. This focusses on developing a risk-based culture of decision making and using the most appropriate mitigation strategies under the ‘5Ts’ approach: (i) treat the risk; (ii) tolerate the risk; (iii) terminate the risk; (iv) transfer the risk; and (v) transform the risk.
5. Due Diligence Processes
Our due diligence processes help us to monitor compliance with our policy commitments, as well as identifying and responding to any modern slavery risks that we encounter in practice. These include:
- Supplier selection – as well as commercial factors, our purchasing teams must consider supplier reputation and background, as well as broader social responsibilities, as part of the process of selecting new suppliers. This includes requiring prospective suppliers to demonstrating the measures taken to manage modern slavery risks.
- Supplier Due Diligence – all new suppliers must go through appropriate due diligence, which includes a supplier due diligence questionnaire.
- Enhanced Due Diligence checks – these are carried out on significant contracts and include additional oversight, more stringent approval processes, the use of risk screening tools and external due diligence providers.
- Contractual Controls – supplier agreements include anti-slavery clauses aligned with international human rights expectations. This includes giving us the right to terminate the commercial partnership with suppliers who breach of the clause.
6. Identified Risks and How We Manage Them
Overall risk profile
Our organisation is generally low risk, given the nature of our services and the fact that we do not operate complex supply chains. However, we have identified: (i) school uniforms as a potential higher risk area; and (ii) cleaning / catering services as medium risk areas.
Higher-risk area: school uniforms
Textile production can present elevated risks due to higher exposure to child labour and forced labour in some markets.
Risk mitigation measures:
- We do not operate complex supply chains and our school procurement teams will have close working relationships with the relevant suppliers. Further, there is considerable oversight of these activities from our specialist regional and central teams.
- Training for relevant staff.
- Evidence-based due diligence during tender processes supported by clear procedural safeguards and controls.
- Application of risk screening tools and country risk indices where necessary.
- Periodic evaluations and audits where necessary.
Medium risk areas: cleaning / catering services
Cleaning and catering services can involve manual, or seasonal, labour that is vulnerable to exploitation.
Risk mitigation measures:
- We do not operate complex supply chains and our school procurement teams will have close working relationships with the relevant suppliers. Further, there is considerable oversight of these activities from our specialist regional and central teams.
- Training for relevant staff.
- Evidence-based due diligence during tender processes supported by clear procedural safeguards and controls.
- Application of risk screening tools and country risk indices where necessary.
- Periodic evaluations and audits where necessary.
7. Measuring Effectiveness
We use a range of qualitative and quantitative measures to monitor the effectiveness of our policies and procedures:
- Training - completion rates for relevant staff.
- Document Management System – we maintain a document management system to ensure that the inclusion of anti-slavery clauses in school contracts can be reviewed and managed.
- Monitoring and Oversight - as indicated above, there is considerable oversight from our specialist regional and central teams, particularly in relation to higher risk areas. This includes supplier evaluations to assess compliance with modern slavery and ethical procurement standards.
- Compliance Certifications – our central compliance team periodically requests management certifications from our schools in respect of both modern slavery risks and significant contracts.
- Whistleblowing concerns – our whistleblowing hotline is available to staff and third parties to allow confidential reporting of any ethical concerns. No reports concerning modern slavery were made to the hotline during Financial Year 2025.
- Internal Audit – compliance with these policies and procedures is monitored by our Internal Audit team, which is independent of management and has a direct reporting line to the Chair of our Audit and Risk Committee.
8. Training
Modern slavery awareness training forms part of NAE’s new joiner induction programme, which is mandatory for all new staff. This ensures a consistent understanding of the risks, indicators and reporting expectations across NAE. We also provide more targeted and role-specific training for colleagues directly involved in procurement, contract management or oversight of high-risk suppliers. This equips those colleagues with the practical knowledge needed to identify potential concerns and escalate any issue through appropriate reporting channels.
9. Future Commitments
To align with government recommendations for continuous improvement, we plan to focus on the following areas over the next 12 months:
- Providing ongoing support and training opportunities to staff to ensure we are addressing modern slavery in our supply chain.
- Continuing to ensure that modern slavery risks are addressed during our procurement process by applying enhanced due diligence on potentially high-risk contracts so that we evaluate relevant suppliers before they enter our supply chain.
- Responsibility for preventing modern slavery involves several functional areas across NAE. We see this as a strength as it ensures that there are multiple lines of defence to identify potential areas for concern, but we will work to document clearer roles and responsibilities across NAE.
- Blacklisting any organisations found to be non-compliant with our policies and standards.
10. Governance and Approval
This statement has been reviewed by senior leadership and approved by the Board of Directors of Nord Anglia Education Limited.
