Modern Slavery Statement

This statement is made as part of Tradewind Recruitment and Sanza Teaching Agency's commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).  It summarises how Tradewind Recruitment and Sanza operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified, how we monitor them, and how we train our staff.

This statement is published in accordance with section 54 of the Act and relates to the financial year 1 September 2025 to 31st August 2026. 

1. Our Organisation, Business, and Supply Chains

a. Organisational Structure and Business

Tradewind Recruitment and Sanza Teaching Agency are education recruitment companies providing staffing and recruitment services to schools, colleges, academies, and other educational institutions. Tradewind Recruitment is part of the wider Abaco Recruitment Limited.

Our core activities include:

• Recruiting teachers, teaching assistants, and education support staff
• Providing temporary, contract, and permanent placements
• Supporting clients across early years, primary, secondary, and further education sectors

Our operations are primarily based in England and Wales, with recruitment activities managed by internal staff and consultants.

Supply Chains

Our supply chains include:

• Candidate sourcing platforms and job boards
• Payroll providers and umbrella companies
• Pre-employment screening and compliance providers (e.g. DBS checks, vetting services)
• IT systems, software providers, and professional services
• Office services and facilities suppliers

We do not engage in overseas manufacturing or high-volume labour supply, but we recognise that risks may still exist, particularly within third-party service providers.

As part of our business, we also work with the following organisations: 

·       Recruitment and Employment Confederation

Policies in Relation to Slavery and Human Trafficking

Relevant Policies

We operate a zero-tolerance approach to modern slavery and human trafficking. Our commitment is supported by the following policies and principles:

• Modern Slavery and Human Trafficking Policy
• Ethical Recruitment Policy
• Safeguarding and Whistleblowing Policy
• Code of Conduct for Employees and Suppliers
• Equality, Diversity, and Inclusion Policy

These policies ensure that:

• All work is freely chosen
• No employee or candidate is subject to forced labour, coercion, or exploitation
• Workers are not required to pay recruitment fees
• Identity documents are never retained as a condition of employment 

Policy development and review

Tradewind Recruitments’ policies are established by our directors and senior leadership team, based on advice from HR professionals, industry best practices and legal advice.  We review our policies regularly or as needed to adapt to changes.  

Due Diligence Processes

Due Diligence in Business and Supply Chains

We have implemented due diligence procedures to identify and manage modern slavery risks, including:

• Rigorous right-to-work checks and identity verification for all candidates
• Compliance with safer recruitment and safeguarding standards
• Vetting of suppliers before onboarding, including contractual assurances of compliance with the Modern Slavery Act
• Ongoing monitoring of key suppliers, particularly payroll and umbrella companies
• Clear reporting and escalation procedures for concerns

Where appropriate, contracts with suppliers include clauses requiring adherence to anti-slavery laws and ethical labour practices.

Risk Assessment and Management

Risk Areas and Mitigation

We recognise that the risk of modern slavery may arise in the following areas:

• Temporary and agency worker arrangements
• Use of third-party payroll or umbrella companies
• External service providers operating in lower-regulated sectors

To assess and manage these risks, we:

• Conduct risk-based supplier assessments
• Avoid working with suppliers who charge candidates fees or operate non-transparent employment models
• Regularly review recruitment practices to ensure compliance with ethical standards
• Encourage candidates and workers to raise concerns without fear of retaliation

Any identified risks are addressed promptly, and suppliers who fail to meet our standards may be removed from our supply chain.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain.  However, we continue to be alert to the potential for problems. 

Our staff are encouraged to bring any concerns to management's attention. 

Effectiveness and Performance Measurement

Measuring Effectiveness

We measure the effectiveness of our approach to preventing modern slavery through:

• Zero tolerance of confirmed modern slavery incidents
• Regular internal audits of recruitment and compliance processes
• Supplier compliance reviews and contract renewals
• Monitoring complaints, whistleblowing reports, and safeguarding concerns
• Management review of policy implementation and improvements

We are committed to continuous improvement and will update our processes where gaps or risks are identified.

Training and Capacity Building

Training and Awareness

All our staff receive training and support appropriate to their role.  In particular:

·      Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.

·      Our recruiters, HR personnel, and staff involved in our procurement and supply chains undertake training courses that include guidance around modern slavery and human trafficking, as well as other broader human rights issues.

·       All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking so that they can bring any concerns they have to the attention of management.

 As part of this, our staff are encouraged to discuss their concerns.  Training is refreshed annually.

Governance and Responsibility

Responsibility for this policy and its implementation sits with senior management. We are committed to reviewing this statement annually and updating it as necessary to reflect changes in our business, supply chains, or legal obligations.

This policy has been approved by the Board of Directors.