Supplier Due Diligence

1. Introduction & Purpose

Brity Group Limited trading as Brity is committed to maintaining the highest standards of integrity, ethics, and compliance in all our business relationships. This policy establishes our framework for assessing, approving, and monitoring suppliers and third parties.

This policy supports our obligations under the Modern Slavery Act 2015, Bribery Act 2010, and our commitment to safeguarding, health and safety, and quality standards.

2. Scope & Definitions

This policy applies to all third parties that provide goods, services, or support to Brity Group Limited, including:

Key Definitions

• Supplier: Any organisation or individual providing goods or services to Brity Group Limited, whether paid or unpaid, including contractors, freelancers, and partners
• Third Party: Any external party we engage with for business purposes
• Due Diligence: The process of investigating and evaluating a potential partner
• High-Risk Supplier: Suppliers requiring enhanced scrutiny due to nature of work, geography, or sector

3. Risk Assessment Framework

All suppliers and third parties are categorised by risk level, which determines the extent of due diligence required before engagement and the frequency of ongoing monitoring.

Risk Categories

Risk Indicators

The following factors increase a supplier's risk rating:

• Operating in sectors known for exploitation (agriculture, hospitality, care)
• Use of temporary, agency, or zero-hours workers
• Complex subcontracting arrangements
• Operating in countries with weak labour protections
• Previous compliance issues or negative publicity
• Lack of transparency in business practices

4. Supplier Vetting Process

Before engaging any new supplier or third party, we conduct proportionate due diligence based on their risk category.

High-Risk Supplier Checks

• Company registration and financial health verification
• DBS checks for staff with learner contact
• Insurance verification (professional indemnity, public liability)
• Reference checks from similar clients
• Modern slavery statement review
• Health and safety documentation
• Qualification and accreditation verification

Trainer-Specific Requirements

5. Compliance Checks

Depending on risk category, we verify compliance with:

6. Ethical Standards

We expect all suppliers to uphold ethical standards including:

• Fair treatment of workers: Payment of at least minimum wage, reasonable working hours, safe conditions
• No modern slavery: Zero tolerance for forced labour, human trafficking, or exploitation
• Environmental responsibility: Consideration of environmental impact
• Anti-bribery and corruption: No offering or acceptance of bribes
• Data protection: Appropriate handling of personal data

7. Contractual Requirements

All supplier agreements include clauses covering:

• Compliance with this policy
• Anti-bribery and corruption commitments
• Modern slavery provisions
• Data protection obligations
• Right to audit
• Termination for non-compliance
• Reporting obligations

8. Ongoing Monitoring & Review

We also conduct ad-hoc reviews following any concerns, incidents, or significant changes in supplier circumstances.

9. Non-Compliance & Termination

Where non-compliance is identified, we will:

• Investigate the nature and extent of the breach
• Request corrective action and evidence of remediation
• Consider suspension of the relationship pending resolution
• Terminate the contract for serious or persistent breaches
• Report to relevant authorities where required by law

10. Record Keeping

We maintain records of all supplier due diligence, approvals, contracts, and monitoring activities. Records are retained for 6 years from the end of the supplier relationship and handled in accordance with our Privacy Policy.

11. Roles & Responsibilities

12. Policy Review

This policy is reviewed annually or following significant changes to legislation, regulations, or business operations. The next scheduled review is January 2027.

13. Contact Information