Modern Slavery and Human Trafficking Policy
Last Updated On 11th September 2025
1. Policy Statement
This Modern Slavery and Human Trafficking Policy affirms the commitment of ActionCOACH UK and its affiliated
franchisees across the UK (“we”, “us”, or “our”) to acting ethically and with integrity in all our business relationships.
We have a zero-tolerance approach to modern slavery and are dedicated to implementing and enforcing effective
systems and controls to ensure it is not taking place anywhere within our own business or in any of our supply chains.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery,
servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person's
liberty by another in order to exploit them for personal or commercial gain.
As a provider of business coaching services, our operational model is primarily based on intellectual capital and
human expertise. However, we recognise that no organisation is immune to risk and are committed to ensuring
transparency and ethical practices throughout our organisation and supply chain.
This policy applies to all employees, coaches, subcontractors, and third-party suppliers globally. While we may not
meet the £36 million turnover threshold requiring a legal modern slavery statement, we voluntarily adopt these best
practices in full to uphold ethical governance
2. Our Business and Structure
ActionCOACH UK is the master franchisee for the ActionCOACH brand in the United Kingdom. Our business operates
through a network of franchised business coaches who provide coaching, mentoring, and business growth services
to small and medium-sized enterprises (SMEs) across the United Kingdom.
Our supply chains include, but are not limited to:
• Franchisees: Independent franchise owners who deliver our services.
• People & Recruitment: Suppliers for the recruitment of our central team and franchisee recruitment.
• Professional Services: IT providers, software licensors (e.g., CRM systems), marketing agencies,
telecommunications providers, and office facilities management.
• Goods & Merchandise: Suppliers of branded merchandise and marketing materials.
3. Responsibility for the Policy
The Board of Directors of ActionCOACH UK has overall responsibility for ensuring this policy complies with our legal
and ethical obligations, and that all those under our control comply with it.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this
policy.
4. Compliance with the Law
We commit to complying with the requirements of the Modern Slavery Act 2015. This policy applies to all persons
working for us or on our behalf in any capacity, including employees at all levels, directors, officers, franchisees,
agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party
representatives, and business partners.
5. Our Commitments
To identify and mitigate the risk of modern slavery in our business and supply chains, we will:
• Due Diligent: Where appropriate, implement robust due diligence processes for taking on new franchisees
and suppliers, particularly in key risk areas.
• Risk Assessment: Conduct periodic assessments of our business and supply chains to identify and evaluate
potential risk areas.
• Contractual Controls: Where appropriate, seek to include anti-slavery provisions in our contracts with
franchisees and suppliers, requiring them to adhere to the principles of this policy.
• Training & Awareness: Where appropriate, provide training to our central team and guidance to our
franchise network on modern slavery and the specific risks relevant to our industry.
• Reporting & Whistleblowing: Encourage the reporting of any concerns regarding modern slavery and protect
individuals who speak up in good faith through our Whistleblowing Policy.
• Performance Indicators: Where appropriate, use key performance indicators (KPIs) to measure how effective
we have been in ensuring modern slavery is not taking place in our business or supply chains.
6. Franchisee and Supplier Adherence to Our Values
We expect the same high standards from all our franchisees, contractors, suppliers, and other business partners. We
will not support or deal with any business knowingly involved in modern slavery.
As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or
trafficked labour, and we expect our suppliers to hold their own suppliers to the same high standards.
7. Training and Communication
Awareness of this policy forms part of the induction process for all individuals working in our central support team.
Regular training on the issue of modern slavery and the specific risks relevant to our business model will be provided
as necessary.
Our franchise network will be communicated with regularly to ensure they understand their role in upholding these
standards, both within their own coaching practices and with their clients.
8. Reporting Modern Slavery
We have an open-door policy and encourage all team members, franchisees, and stakeholders to report any
suspicion of modern slavery or human trafficking in any part of our business or supply chains at the earliest possible
stage.
We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their
suspicion that modern slavery is or may be taking place. Detrimental treatment includes dismissal, disciplinary action,
threats, or other unfavourable treatment connected with raising a concern.
Concerns can be raised with your direct manager, a company director, or through our confidential whistleblowing
channel: freedom@actioncoach.com
9. Breach of this Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or
gross misconduct.
We may terminate our relationship with franchisees, individuals, and organisations working on our behalf if they are
found to have breached this policy.
10. Review
This policy will be reviewed annually by the Board of Directors to ensure its continuing suitability and effectiveness.
We will update our practices and this statement to reflect best practice and legal developments.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and
human trafficking statement for the current financial year.