Modern Slavery Policy

FITPRO-X is committed to acting ethically and with integrity in its business relationships. Modern slavery has no place in our operations, education delivery, recruitment activity or supply chains.

This policy sets out the standards expected of everyone working for or with FITPRO-X and the steps used to identify, prevent, report and address modern slavery risks.

This policy applies to all FITPRO-X directors, employees, agency workers, tutors, assessors, mentors, contractors and volunteers. It also informs the standards expected from suppliers, partner gyms, technology providers, recruitment partners, education partners and other third parties.

• Slavery, servitude and forced or compulsory labour.
• Human trafficking, including arranging or facilitating travel with a view to exploitation.
• Debt bondage, withholding identity documents, threats, coercion or restriction of movement.
• Labour exploitation, including unlawful recruitment fees, excessive working hours, non-payment or underpayment and abusive working or living conditions.
• Child labour or work that is unlawful, harmful or interferes with education and development.

FITPRO-X provides fitness education, online learning, practical assessment, mentoring, career pathways and recruitment or placement support. Delivery may involve staff, self-employed professionals, gym partners, awarding organisations, funders, technology providers, marketing providers and other suppliers.

Potential risk areas may include outsourced services, temporary or agency labour, cleaning and facilities services, branded merchandise and clothing, events, digital supply chains, overseas services, recruitment introductions and suppliers operating through multiple subcontracting tiers.

• No person will be required to work through force, threat, coercion, deception, debt or retention of identity documents.
• Workers must receive clear terms, lawful pay and freedom to leave employment or an engagement in accordance with law and contract.
• FITPRO-X will not knowingly use recruitment arrangements that charge workers unlawful fees or create exploitative debt.
• Concerns may be raised without retaliation. Reports will be taken seriously and handled sensitively.
• Commercial pressure, price, deadlines or supplier relationships do not justify ignoring credible indicators of exploitation.

• Identity and right-to-work checks are completed where legally required and records are handled securely.
• Employment and contractor arrangements must be documented, transparent and approved through the appropriate process.
• No manager or intermediary may retain a worker’s passport, identity document, bank card or personal property as a condition of work.
• Pay, deductions and working arrangements must comply with applicable law. Unexplained deductions, payment through another person or pressure to work excessive hours must be investigated.
• Recruitment and placement partners must not mislead candidates about roles, earnings, fees, visas, accommodation or working conditions.

Due diligence will be proportionate to the nature, location, value and risk of the supply. Higher-risk arrangements may require additional evidence, contractual commitments, audit rights or senior approval.

• Confirm supplier identity, ownership, location and use of subcontractors where relevant.
• Consider sector, geographic, workforce and recruitment risks before appointment and at renewal.
• Include appropriate obligations to comply with modern slavery, employment and human rights law.
• Require prompt reporting of suspected exploitation connected with FITPRO-X services or supply chains.
• Reserve the right to request corrective action, suspend activity or terminate relationships where serious concerns are not resolved.

• A person appears frightened, controlled, withdrawn or unable to speak freely.
• A third party holds identity documents, controls wages, transport or accommodation, or answers all questions for the person.
• Workers report recruitment debt, threats, withheld wages, unsafe accommodation or inability to leave.
• Working hours, pay, deductions or conditions appear inconsistent with what was promised or with legal requirements.
• A supplier refuses reasonable transparency about labour providers, subcontractors or worker conditions.

Anyone who suspects modern slavery must report it promptly to a director or senior manager. Reports may also be made through the FITPRO-X whistleblowing route or by emailing [email protected] and marking the message “Confidential: Modern Slavery Concern”.

Where someone is in immediate danger, call 999. FITPRO-X will not confront a suspected exploiter where doing so could increase risk. Information will be shared only with people or authorities who need it to protect individuals, investigate concerns or meet legal duties.

• Record the concern factually, preserve relevant information and assess immediate safety.
• Escalate to appropriate authorities, law enforcement, safeguarding services, funders or contractual partners where necessary.
• Protect potential victims from retaliation and avoid action that could worsen their position.
• Investigate internal or supplier control failures and agree corrective actions with clear deadlines.
• Suspend or terminate a relationship where exploitation is substantiated or a supplier refuses meaningful remediation.
• Prioritise the safety and rights of affected people, not only contractual or reputational considerations.

Relevant staff will receive proportionate guidance on modern slavery indicators, safe reporting and procurement or recruitment responsibilities. Training will be refreshed where risks, law or business activities change.

The Senior Management Team will review the effectiveness of this policy using proportionate indicators. These may include supplier due diligence completion, contractual coverage, training completion, reported concerns, response times, corrective actions and recurrence of issues.

A breach by an employee may result in disciplinary action, including dismissal. A breach by a contractor, supplier or partner may result in corrective action, suspension, termination and referral to relevant authorities. Action will be fair, proportionate and lawful.

The Board or Senior Management Team owns this policy. It will be reviewed at least annually and sooner if FITPRO-X enters a higher-risk market, changes its supply chain materially, receives a credible concern or becomes subject to a statutory statement requirement.

Where a statutory modern slavery statement is required, it must be approved, signed and published in accordance with the applicable legislation and guidance.

References are included for governance and review. The policy should be updated where legislation, guidance or contractual requirements change.

• Modern Slavery Act 2015
• Home Office guidance: Transparency in supply chains – a practical guide
• UK collection: Modern slavery