This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Rinova has taken and continues to take to ensure that modern slavery and human trafficking are not taking place within our business or supply chains.
Rinova supports the Modern Slavery Act 2015 and opposes modern slavery and human trafficking. We are committed to ensuring that modern slavery and human trafficking have no place within our supply chain and operations.
Our business and supply chains
Rinova is committed to conducting business in an ethical and responsible manner. We operate in the education sector and have supply chains that include subcontractors, equipment providers, office supplies, and IT services. We recognise the importance of maintaining the highest standards of ethical conduct and integrity in all our business activities.
Our policies
We have implemented the following policies and processes to prevent and address modern slavery and human trafficking:
- Code of Conduct – which requires all employees, subcontractors and stakeholders to adhere to our ethical labour practices and respect for human rights.
- Whistleblowing Policy – which outlines the confidential mechanism for employees, service users and other stakeholders to report any concerns.
- Robust recruitment procedure – compliant with UK employment legislation and incorporating pre-employment checks, e.g., right to work in the UK, references. Bank information is verified to ensure salary payment is going to an individual’s account and DBS checks are undertaken for relevant job roles.
- Robust procurement procedure – outlining subcontractor due diligence required to support ethical procurement and eliminate any risks relating to modern slavery or human trafficking.
- Standard terms and conditions for the procurement of subcontractors, consultancy, goods and services to ensure appropriate provisions are in place in relation to modern slavery. All subcontractors and suppliers must comply with the Modern Slavery Act 2015.
Due diligence and risk assessment
We conduct proportionate due diligence based on the nature and scale of each supplier relationship. This includes communication to confirm compliance with our anti-slavery standards.
Training and Awareness
We provide training to our employees to ensure they are aware of the risks of modern slavery and human trafficking and understand how to identify and report potential issues. This training includes:
- Information on the legislation and Section 54 of the act
- How employees can identify and prevent slavery and human trafficking
- What employees can do to raise concerns about potential modern slavery or human trafficking issues
- What external help is available, e.g., the Modern Slavery Helpline
Updates and reminders are communicated via annual refresher training and internal communication channels.
Monitoring and Reporting
We continuously monitor our supply chains and business operations for anti-slavery compliance. We require our subcontractors and suppliers to report on their compliance with our standards and to notify us immediately of any potential breaches. Any reported incidents are thoroughly investigated, and appropriate action is taken.
Continuous improvement
We are committed to continually improving our practices to combat modern slavery and human trafficking. We review and update our policies and procedures annually to ensure they remain effective and aligned with best practices. Our next review will occur in August 2026.
This statement applies to all organisations within the Rinova Group. For the avoidance of doubt, where ‘Rinova Ltd’ is referenced this shall be understood to also apply to Rinova Community CIC and Rinova Malaga S.L.
Date Created: 01/12/2015
Last Review: 01/09/2025
Next Review: 01/09/2026
This policy has been reviewed and approved by the Board of Rinova Ltd.Richard Parkes, Chair and Director.