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Modern Slavery Policy

Anti-Slavery Policy (“Policy”)

It is a priority for Sebina (“we, us, our”), a provider of services, to ensure we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our business and from our suppliers and customers. We make this statement voluntarily as it is important to us to show that our business and everyone connected with it will not tolerate human trafficking or modern slavery.
We operate in the low risk e-learning sector and the electronic nature of our online based service encourages low carbon emissions. We communicate this Policy across our business, publishing this statement on our website and keep it under review.

Our policies on slavery and human trafficking

Whilst our courses, webinars and online materials are produced entirely in-house, in order to provide our service, we work with a range of core suppliers from industry specialists to service providers. All our relationships with industry specialists are based on our shared values, growth and commitment to the highest levels of performance.
We are commitment to ensure that there is no modern slavery or human trafficking in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business relationships.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk aim to:

  • Identify and assess potential risk areas in our business and in our business relationships with suppliers and customers.
  • Mitigate the risk of slavery and human trafficking occurring in our business and in our business relationships with suppliers and customers.
  • Prevent forced labour.
  • Provide a safe working environment.
  • Ensure employees are at least 18 years of age and eligible to work.
  • Monitor potential risk areas in our business and in our business relationships, and provide appropriate training by making them aware of our Policy, and expect the same standards in return.
  • Protect whistle blowers.
  • If a risk was identified in a potential new supplier, we would not commence activity until reassurances were met.
  • Should evidence of slavery or human trafficking come to light with an existing supplier or customer, we will enforce zero tolerance and immediately terminate the relationship.

Supplier adherence to our values and ethics

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics we have in place compliance personnel which consists of involvement from the following departments:

  • Legal
  • Audit and compliance.
  • Human resources.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide regular training to our staff. We also require our business partners to provide training to their staff and suppliers and providers.

Statement

This voluntary statement is made in accordance with section 54(1) of the Modern Slavery Act 2015.

This statement was approved by: Sebina Noreen Malik (Director) 

CODE OF CONDUCT AND ETHICS

  • Sebina (“we, us, our”) operate and pride ourselves values on our reputation for acting fairly and ethically wherever we do business. Our reputation is built on our values as a company, the values of our employees and our collective commitment to acting with integrity throughout our business and day-to-day work.
  • We condemn corruption in all its forms and we will not tolerate it in our business or in those we do business with including any violations of human rights, distorts markets, organised crime and threats to human security.
  • This statement of ethics is a statement made by us through our senior management which sets out the ethical basis on which it does business and its approach to dealing with bribery and corruption.
  • We seek to ensure that bribery prevention policies and procedures are embedded and understood and effectively communicated to all relevant staff through internal communication, including training, that is proportionate to the risks we face.

WHO THIS CODE APPLIES TO

  • This Code applies to all persons working for us, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns and individual temporary or fixed term contractors, wherever located.
  • This Code does not form part of any contract of employment or contract to provide services and we may amend it at any time.

RESPONSIBILITY FOR THE CODE

  • The board of director has overall responsibility for ensuring the Code complies with our legal and ethical obligations, and that all those under our control comply with it.
  • This Code will be monitored for its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in managing ethics and conduct.
  • Management at all levels are responsible for ensuring those reporting to them understand and comply with this Code and are given adequate and regular training on it and the issues covered by it.

WORKPLACE ENVIRONMENT

Diversity, equity and inclusion – our workplace culture that promotes diversity, equity and inclusion to encourage employee retention, attract the best candidates in recruitment, increase productivity and enhance our business reputation.

    • Diversity: we set target of increasing the percentage of women at senior management level.
    • Equity: we establish a mentoring programme to help increase equality of opportunity for those from ethnic minorities.
    • Inclusion: we set up and support the use of internal network groups aimed at supporting those with particular protected characteristics.
We are committed to providing a working environment free from discrimination, harassment and bullying and ensuring all staff are treated, and treat others, with dignity and respect
We are committed to protecting the health, safety and wellbeing of our staff. We recognise the importance of identifying and tackling the causes of work-related stress. We also recognise that personal stress, while unrelated to the workplace, can adversely affect the wellbeing of staff at work.

BUSINESS PRACTICES

Conflicts of interest

Our employee, you are expected to:

  • Maintain the highest possible standard of integrity in all our business relationships, both inside and outside our business.
  • Reject any business practice which might reasonably be deemed improper.
  • Never use their authority or position for personal gain.
  • At all times, act with impartiality, independence and integrity.
  • Avoid being, or giving the appearance of being, in a position which may result in an actual or perceived detriment to our reputation and/or interests.

Bribery and corruption

  • It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.
  • This policy does not form part of any employee’s contract of employment and we may amend it at any time. It will be reviewed regularly.
  • This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
  • Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. All forms of bribery are strictly prohibited, specifically:
  • give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
  • accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
  • give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;
  • threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Anti-money laundering

We prevent money laundering by meeting the relevant standards on combating money laundering and terrorism financing, including having adequate compliance in place to mitigate the risk of money laundering.