Modern Slavery Policy
Our commitment to tackling modern slavery and human trafficking.
Modern Salvery Policy
Skills Pad Modern Slavery Statement 2026
Last Reviewed: 28/08/2026
Next Review Due: 28/08/2027
Training Code Ltd, trading as Skills Pad (company number 12924476)
Financial year covered: 1 November 2024 to 31 October 2025. Published: 28 August 2026.
1. Introduction
Skills Pad has a zero-tolerance approach to modern slavery. This includes slavery, servitude, forced labour and human trafficking.
Our turnover was £108,659 in the year to 31 October 2025. This is below the £36m threshold in Section 54 of the Modern Slavery Act 2015. We are not legally required to publish a statement. We publish this one voluntarily. It follows the six areas in the Home Office statutory guidance.
2. Our organisation, business and supply chains
- Skills Pad is an adult training provider based at 33 Park Street West, Luton LU1 3BE. We operate only in the UK.
- We train unemployed adults and young people not in education, employment or training. Courses include SIA security, CSCS construction, first aid, health and safety (including IOSH), functional skills, employability and customer service.
- We deliver publicly funded training as a contractor or subcontractor, and commercial courses for employers.
- We have 3 staff. Rana Miah is the sole director and owner.
- We use no recruitment agencies and no external cleaning contractor.
Our main suppliers are:
- awarding bodies (for example Highfield and IOSH)
- freelance and temporary tutors (£15,219 of temporary staff costs in the year)
- PPE and first-aid consumables
- our premises landlord
- software and subscriptions.
3. Our policies
These policies support this statement:
- Safeguarding and Child Protection Policy 2026 (covers modern slavery, trafficking and referral to the National Referral Mechanism)
- Whistleblowing Policy 26
- Safer Recruitment and Selection Policy 26 (identity and right-to-work checks)
- Code of Business Conduct and Ethics
- Equality, Diversity and Inclusion Policy
- Complaints Procedure
Our commitments. Skills Pad does not, and expects its suppliers not to:
- charge workers recruitment fees
- hold workers’ passports or ID documents
- use child labour or force overtime
- stop workers leaving with normal notice, moving freely or joining a union.
We will help any victim to reach support and remedy.
4. Due diligence
- We check identity and right to work for all staff and tutors before they start.
- Staff and tutors arrange their work directly with us, not through a third party.
- We pay at least the National Minimum Wage or National Living Wage. All pay is made by bank transfer, and DBS checks are completed where the role requires them.
- We pay suppliers within 30 days, on average in about 14 days. This avoids putting pressure on small suppliers.
- Not yet in place: our supplier and tutor agreements do not yet include a modern slavery clause. We have not yet mapped our suppliers or checked where PPE is made. These are in our action plan.
- If a concern is raised: we acknowledge it within 24 hours. Concerns can be raised in confidence with the Director on 01582 958844 or info@skillspad.co.uk. If someone is in danger, we contact the police or the Modern Slavery & Exploitation Helpline (08000 121 700) the same day. We work with a supplier that co-operates to fix a problem, rather than dropping it straight away.
5. Risk assessment
Our overall risk is low. We are a small UK service business with a short, UK-based supply chain.
Higher-risk areas:
- PPE and first-aid consumables. These are bought from UK suppliers, but the goods may be made abroad. Gloves in particular are linked to forced labour in some countries. We have not yet checked country of origin.
- Freelance and temporary tutors. Short-term and self-employed work carries more risk of unfair terms.
- Our learners. Many move into entry-level security and construction jobs, where exploitation is known. We treat this as a safeguarding risk.
6. Training
All staff complete external safeguarding and Prevent e-learning, which covers modern slavery, at induction. Completion is recorded in the Safeguarding Training Log 26. The course covers the 11 ILO indicators of forced labour.
7. Key performance indicators
| KPI | Result FY2024-25 | Target 2026-27 |
|---|---|---|
| Staff who completed modern slavery training | 100% | 100% |
| Supplier invoices paid within 30 days | 100% | 100% |
| Main suppliers and tutors with a modern slavery clause | 0% | 100% of new and renewed agreements |
| PPE product lines with country of origin checked | 0% | 100% |
| Modern slavery concerns raised and closed on time | None raised in the year | All closed on time |
8. Action plan 2026-27
| Action | By |
|---|---|
| Add a modern slavery clause to supplier and freelance tutor agreements | 31 January 2027 |
| Check country of origin for PPE and first-aid consumables, and record it | 31 March 2027 |
| Put our 30-day payment terms in writing to suppliers and tutors | 31 January 2027 |
| List our main suppliers and give each a risk rating | 31 March 2027 |
| Publish the next statement within 6 months of our 31 October 2026 year end | 30 April 2027 |
| Annual review of this statement and the KPIs | August each year (next August 2027) |
9. Approval
This statement was approved by the director of Training Code Ltd.
Signed: Rana Miah, Director
Date: 28 August 2026
Next review: August 2027.
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