Modern Slavery Statement

Modern Slavery and Human Trafficking Statement


This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 30 September 2021. 

Treble 2 Ltd (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values. 

Organisational structure

Treble 2 Ltd has business operations in the United Kingdom as well as:

  • European Union
  • United States of America

We operate in the change management and education sector. The nature of our supply chains is as follows: We work with a number of key direct suppliers who supply us with goods, such as equipment for our premises, and services, such as outsourced business processes, IT software and marketing services.


We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. 

These include the following: 

  • Recruitment and selection policy – We ensure individuals and organisations working with us are recruited in a transparent manner.
  • Supplier code of conduct – We require suppliers to confirm and abide by the same code of conduct we do.
  • Whistleblowing policy – We ensure a those working with us are provided with a safe outlet to raise concerns, which are always investigated.
  • Staff code of conduct – All employees are required to agree to the same code of conduct expected of all suppliers and other stakeholders within our control.
  • Procurement policy – We require all links in the procurement chain to confirm and abide by the same code of conduct we do.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures: 

  • Internal supplier audits.

Our due diligence procedures aim to:

  • Identify and action potential risks in our business and supply chains.
  • Monitor potential risks in our business and supply chains
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
  • Provide protection for whistleblowers.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

  • Evaluating the slavery and human trafficking risks of each new supplier.
  • Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.

We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in low-risk industries, such as training services, and in low-risk countries.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.


The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

  • We will contact suppliers to enquire about their modern slavery practices every 6 months.
  • We will carry out a regular audit of suppliers – 50% of suppliers each year.

The statement was approved by the board of directors.

Alan Cowan, Director
Treble 2 Ltd

29th September 2021

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