PeopleCert Modern Slavery & Human Trafficking Statement 2018
This statement is published by PeopleCert Holdings UK Ltd and its relevant subsidiaries (“PeopleCert”). It covers the financial year ending 31 December 2018, which is the first financial year for which the turnover of PeopleCert has required a statement under section 54 of the UK Modern Slavery Act 2015. The board of directors of PeopleCert Holdings UK Ltd has overall responsibility for management of PeopleCert companies, and has approved this statement.
- PeopleCert’s Business
PeopleCert is a global leader in the assessment and certification of professional skills, partnering with multi-national organisations and government bodies to develop and deliver market leading exams worldwide.
PeopleCert develops and delivers a comprehensive range of solutions and services for the secure assessment and certification of professional and language skills. Its key activities include: qualiﬁcation and assessment design and development; secure delivery of internationally-recognised, qualifications / examinations; certification and accreditation; and delivery of information and reporting on examination results.
- Our Policy on Modern Slavery
PeopleCert does not tolerate any form of modern slavery. This commitment is embedded in our Supply Chain Policy and the PeopleCert Code of Ethical Conduct (Code), which applies to all PeopleCert directors, managers, employees, contractors, trainees and volunteers, and to third-party entities and individuals when doing business with PeopleCert. We are not aware of any modern slavery in our supply chain.
Because PeopleCert is a close-knit, medium-sized company (with approximately 340 employees at the end of 2018) which delivers examination and certification services, we believe that most types of modern slavery are highly unlikely in our supply chain. Our work to eliminate modern slavery focuses on fair pay and working conditions among the organisations who distribute our testing services – these appear to be the largest modern slavery risks in our supply chain. We also remain vigilant regarding other types of modern slavery.
With respect to fair pay, it is our policy to pay significantly in excess of the minimum wage for all of our employees: our current policy is that our lowest-paid employees are paid between 10-15% in excess of the minimum wage. We ensure fair working conditions for all of our employees, and we have an admirable record of employee longevity. For companies in our supply chain, the Code and Supply Chain Policy encourage pay of at least the minimum wage and fair working conditions.
- Due Diligence
In the examination and certification business, it is critical to ensure the integrity of all parts of the supply chain. PeopleCert has three main types of third-parties in its supply chain:
• Accredited Organisations and Test Centres: organisations approved by PeopleCert to administer and deliver examinations, and associated training
• Suppliers/Subcontractors: organisations used by PeopleCert for the delivery of standard operational services, such as ICT suppliers, printers and couriers
• External Associates: individuals who provide services that require specific expertise necessary for the delivery of PeopleCert services, such as invigilators, psychometricians and mystery shoppers.
Third parties in PeopleCert’s supply chain are subject to specific selection criteria and processes, described in dedicated procedures and manuals, and designed to detect and prevent the use of inappropriate third parties. PeopleCert conducts extensive efforts to ensure that those in our supply chain meet our high quality standards, and we conduct regular audits of our partner organisations around the world. We believe that these combined efforts are likely to detect any significant instances of modern slavery in our supply chain.
All PeopleCert staff are required to be familiar with the Code (including its provisions on modern slavery). During 2019, PeopleCert will adopt a programme of modern slavery awareness across our partner organizations, including as part of our audit programme.
- Policies and Procedures
In addition to our Code and Supply Chain Policy, the following are in place within PeopleCert and support our commitment to zero tolerance of any form of modern slavery:
• Whistleblowing Policy
• Malpractice Policy
• Safeguarding Policy.