First Steps ED (FSED) fully recognises its responsibilities for Modern Slavery and Human Trafficking whilst an exempt organisation our annual statement sets out what steps we have taken to ensure modern slavery is not taking place in our charity or supply chains and will ensure that:

All staff, volunteers, contractors and trustees are aware of their responsibilities.

Policy Statement

This policy statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Charity’s modern slavery and human trafficking statement for the financial year ending 31 March 2022.

1. First Steps ED Modern Slavery Act Statement

First Steps ED is committed to ensuring modern slavery does not exist in its organisation or supply chains. We constantly strive to develop, policy and procedures to manage the way we obtain our goods and services to keep our supply chains robust. To date we have had no reports of modern slavery within our organisation nor our supply chains.

2. Supply Chain

First Steps ED continues to assess the modern slavery standards of our key suppliers having implemented, in early 2022 more formal, risk-based supplier due diligence process.

All suppliers are issued with contracts referencing First Steps ED sourcing standards and the requirements we expect them to meet on modern slavery. We follow this up with a questionnaire to better understand their environmental and ethical credentials of both their supply chain and production/service facilities. The responses to these questions enable us to identify any supplier who falls short of meeting our requirements and work with them so they can achieve our benchmark.

We remain focused on assessing our high risk spend areas and on raising awareness across all staff, from the Executive team through to everyone at our places to ensure all products and services are sourced and supplied responsibly, ethically and legally.

3. Staff and Volunteer Wellbeing

First Steps ED has a clear framework of rules and behaviours and encourages the reporting of any concerns or breaches so that they can be dealt with appropriately in accordance with our policies and procedures.

We have reviewed and revised our safeguarding policy, procedures, and Quality Management System framework to ensure we recognise, report, and respond to all concerns or incidents of safeguarding. We are committed to keeping all our people safe from harm and abuse, this includes children, adults at risk and anyone who comes into contact with First Steps ED.

We offer an independent and confidential Whistleblowing procedure where staff and volunteers can raise concerns confidentially and anonymously if they wish. Our Staff Handbook also provides staff with a secure way of seeking advice about any modern slavery or human trafficking issues personally affecting them or their families.

First Steps ED checks that staff can demonstrate their eligibility to work in the UK and requires all contractors and temporary staff to undergo an eligibility check before commencing work with the charity. The charity also seeks confirmation from volunteers that they have eligibility to work in the UK. In addition, First Steps ED uses a preferred supplier list to source temporary workers.


Approved by the Board of Trustees of First Steps ED on 27 April 2022 and signed on its behalf by Carolyn Gilby, Chair.