Modern Slavery Statement

This statement has been published in accordance with Section 54 of the Modern Slavery Act 2015. It sets out the steps taken by the Shaw Trust Group, which comprises:

Careers Development Group, Disabled Living Foundation, Forth Sector; Forth Sector Development Limited; Good Work Partners, Homes2Inspire Ltd; Homes2Inspire Services Ltd; Ixion Holdings (Contracts) Ltd; Ixion CG Ltd, Ixion Social Enterprise Ltd, Prospects Distribution Services Ltd, Prospects Education Services Ltd, Prospects Group 2011 Ltd; Prospects Services, Prospects Services Midco Ltd, Shaw Trust International Partnerships Ltd; and Shaw Southern Australia Ltd.

It covers the period August 2025 – August 2026 to prevent Modern Slavery and Human Trafficking in its own business operations and within supply chains.

Introduction

Shaw Trust is fully committed to the Modern Slavery Act 2015 and the duty it places on large organisations to disclose publicly the steps they are taking to prevent modern slavery organisationally and, in their supply chains.

Shaw Trust Policies and procedures include and will continue to be enhanced to ensure that all the required provisions to guide and embed standards of good practice, monitor compliance and prevent modern slavery.

At Shaw Trust we take pride in our ‘charitable heart with a commercial brain’ approach. Our focus is to deliver quality services that also maximise social value and social investment to communities. This approach allows us to meet:

Our Vision

A future where good employment is accessible to all in society irrespective of life circumstances.

Our Mission

To help individuals facing barriers to work and social inclusion to achieve their full potential.

To multiply our social impact by delivering innovative system-change partnerships and programmes.

Business and Operational Structure

Shaw Trust is the UK’s largest Not-for-Profit (NFP) social enterprise in the employment sector and one of the largest charities in the UK. The Shaw Trust Group employs over 2,900 staff.

Shaw Trust owns:

  • Careers Development Group
  • Disabled Living Foundation Ltd
  • Forth Sector
  • Forth Sector Development Limited
  • Good Work Partners
  • Homes2Inspire Ltd
  • Homes2Inspire Services Ltd
  • Ixion CG Ltd
  • Ixion Holdings (Contracts) Limited
  • Ixion Social Enterprise Limited
  • Prospects Distribution Services Ltd
  • Prospects Education Services Ltd
  • Prospects Group 2011 Ltd
  • Prospects Services
  • Prospects Services Midco Ltd
  • Shaw Education Trust
  • Shaw Trust International Partnerships Ltd
  • Shaw Southern Australia Ltd

Shaw Trust uses several suppliers across all its functions, to enable it to carry out its charitable and business purposes.

Key Focus Areas

In 2025/2026 we will focus on:

  • Understanding the Risk of Modern Slavery with Shaw Trust Suppliers – Through the completion of a desk- based research exercise identifying risk levels against our current supply chain
  • Procurement – Additional questions will be added during the procurement process to embed PPN 02/23 Tackling Modern Slavery in Government Supply – guidance.
  • Contracting and policy development – Continual enhancement of due diligence exercises to align with good practice guidance to support identifying risk levels against our current supply chain
  • Raising awareness and incident reporting – Review the mandatory modern Slavery training package and create/deliver a 12-month comms plan across the group to raise awareness of topic areas i.e. debt bondage. Introduce online incident reporting tool for Commercial Contracting Supply Chain Partners and implement a Service Level Agreement for responding to suspected instances of modern slavery
  • Data and Insight – Scrutinise quarterly incident reporting data through the audit and risk committee and the strategic safeguarding group.
    Quality check reported incidents and risk management.

Governance Structure

  • Our organisational lead on Modern Slavery and Human Trafficking is the Chief Strategy and Risk Officer. (CSRO)
  • We have a named lead for Safeguarding within the Board of Trustees.
  • We have a Group Safeguarding Lead.
  • We have named Designated Leads for safeguarding at directorate level.
  • Our work in relation to Modern Slavery is supported and guided within the following policies:
  1. Shaw Trust Safeguarding Policy and Framework.
  2. Safer Recruitment Policy.

Policy, performance, and risk is reported and monitored through the following framework.

Responsible Recruitment

Shaw Trust have a Safer Recruitment Policy which includes the following information:

  • We only use recruitment agencies who are on our preferred supplier list and have gone through our due diligence process.
  • Independent teams who employees can contact, e.g. HR Support Services (HRSS) for queries.
  • Provide mandatory training for hiring managers on Safer Recruitment.
  • Complete background checks on new joiners – DBS and reference checks.
  • Candidates must have the right to work in the UK (Right to Work ID must be provided at the offer stage). We ask this during the application process and auto reject applicants who do not have the right to work in the UK.

Training and Awareness

All Shaw Trust Staff complete a Modern Slavery training module within the first six months of working with Shaw Trust. The module is reviewed annually by the Group Safeguarding Lead.
Training completion is monitored by Shaw Trust Learning and Development Team and reported into the Audit and Risk Committee quarterly.

Staff have access to information and resources from the Home Office and the NGO Anti-slavery international organisation (www.antislavery.org) via our Safeguarding Intranet page, the Loop.

Shaw Trust provide the following information to staff throughout the year which includes Modern Slavery topics:

  • Monthly communications on topic areas.
  • Resources within the document hub.

Due Diligence

Shaw Trust (including its subsidiary legal entities) operates under a Supply Chain Management Framework (SCMF). The SCMF aims to set a consistent standard for the management of Supply Chain Partners (SCP) across Shaw Trust and thereby drive the behaviours required to operate to the benefit of our commissioners, adhere to key performance expectations and legislation, and seeks to ensure we are providing value for money at every stage. Within the SCMF we set out our approach to due diligence of our SCPs.

Selection, Due Diligence & On-boarding

When identifying SCPs for inclusion as part of our commissioner-based contracts, we will hold an Expression of Interest process led by our Partnerships Team or if new partners are required during a contract period, we will lead an Invitation to Tender procurement process.

We expect high standards and assurances regarding Modern Slavery, Safeguarding and Responsible Recruitment across our supply chain as part of this process. Ahead of onboarding a partner, we will gather and assess a range of information including policies and processes which are assessed by Subject Matter Experts from across the organisation. All partners prior to onboarding are signed off by a senior leader as part of the delegated authority process.

We will always work with our commissioners and supply chain partners to ensure fair pricing under the principles of the UK Prompt Payment Code to minimise the risks of Modern Slavery.

Key Performance Indicators

Shaw Trust is committed to monitor a set of key performance indicators in relation to Modern Slavery. These include:

  • The delivery and monitoring of all staff and volunteers completing the mandatory Modern Slavery training module.
  •  Reporting and monitoring all Modern Slavery concerns raised through our central incident reporting function to the Risk and Audit committee and the Strategic Safeguarding Group.
Authorised by:
This statement was approved by the Shaw Trust Board of Trustees on 26 February 2025 and signed on their behalf by:
 
 
Chris Luck signature

Chris Luck CB MBE MA MPhil
Chief Executive

Carl Nicholson
Trustee

Carl is a senior managing director at Accenture, with c 30 years’ deep commercial experience in delivering large client contracts, and leading multi-disciplinary, global service delivery teams. As the global Inclusion & Diversity sponsor, Carl is passionate about creating a culture and environment that enables colleagues from all walks of life to achieve their professional aspirations. 

Carl joined Shaw Trust as a Trustee in March 2024, relishing the opportunity to bring his commercial expertise to support Shaw Trust’s goals and aspirations, in an environment where he can tangibly give back to society.

Christine Swabey
Trustee

Christine joined Shaw Trust in March 2024. Previously, she has operated at a senior level in the commercial, public and third sectors, notably in education, health and social care. She is passionate about the role of the Board in upholding values and supporting strategic ambition to enhance impact for all users.

Christine is currently Chair of St. George’s University of London, a specialist healthcare university based in South West London. She has led discussions on a merger with City University, which when implemented, will create the UK’s most comprehensive educator of the healthcare workforce. She has been a Board member of a number of NHS and charitable organisations, providing care to those experiencing poor health, mental and physical, and those living with disability. She was Chief Executive of Autistica, the UK’s leading research charity dedicated to improving lives of people with autism. That experience underscored her belief in the strategic importance of research in driving change.

In the schools sector, Christine is an experienced school governor and recently chaired the Independent Schools Inspectorate. She has first-hand experience of safeguarding from both a regulatory and provider perspective, including residential care settings.

She is genuinely excited about contributing to the Shaw Trust Mission to enable everyone to fulfil their potential through access to purposeful and life affirming employment.

Greg Allen
Trustee

Greg is an experienced CEO, chair, and Trustee/non-executive director. He has also been a Professor of Practice (Leadership) at the University of Exeter Business School since 2020. He is passionate about improving the lives of people of all ages and supporting the development of young people in their work and employment.

With a career spanning over 30 years, his board roles have covered the commercial (plc), public, third sectors and consultancy, with over 20 years working across health and care. Most recently, he has been Interim CEO of Blind Veterans UK, following four years as CEO of Future Care Capital. Both are health and care charities with long and rich histories.

He joined Shaw Trust as a Trustee in early 2024, following previous Trustee roles at Hospiscare in Devon and the national charity Arthritis Action. Other previous executive roles include CEO of the government’s national Centre for Workforce Intelligence, senior civil servant at the Department of Health, a national director of Nuffield Health and private banker at Coutts & Co. In his early career, he qualified as a teacher and served in the UK and abroad as an Officer in the British Army.

He is a keen road cyclist and Francophone/Francophile.

James Stewart OBE
Trustee

James became a Trustee in 2021 after a 30 year career spanning the public and private sectors. He started in the banking sector, led Partnerships UK and Infrastructure UK, and then spent ten years at KPMG finishing as a Vice Chair and member of the UK Board.

Much of James’ career has been spent in the pursuit of improving public services and he has been involved in the development of many of the leading UK infrastructure projects and programmes including Crossrail and HS2. James believes that skills are a key enabler to the regeneration and growth of the UK economy and helping young people to have the opportunity to acquire skills and have the best chance of employment is his motivation for joining Shaw Trust. He is attracted by the Shaw Trust operating model and believes that social enterprises can have a greater role in delivering public services in the future.

Steve Shaw
Trustee

Steve is passionate about using his extensive HR Leadership experience to make a positive difference to the lives of others. Throughout a career spent at the helm of global matrix organisations devising and implementing expansive change initiatives, Steve has utilised extensive HR experience to deliver substantial revenue, growth, and organisational development.

Steve has represented HR in Board positions for more 15 years, most recently as Chief HR Officer for the Apogee Corporation, leading on HR, real-estate, and environmental strategies.

Steve brings experience of working within the charity sector, having in the past managed and held leadership roles within National Citizens Advice Bureau for 6 years and performed non-executive director roles for Presentation Housing Association for four years, with a focus on the vulnerable and disadvantaged. Steve believes that the seamless blend and contribution of paid employees and volunteers providing valued and sought-after services can bring unique challenges to the workplace along with passion and devotion to the delivery of quality. This generates a unique culture, with people that have insights, motivation and experiences that utilised well, make an incredible difference to society. Steve believes in the importance of rigour and best use of available funds to maximise an organisation’s ability to facilitate this. Steve’s expertise in organisational consolidation following acquisitions, business transformation, continuous improvement and career pathing for employees will all support the delivery of Shaw Trust’s Vision 2030: Strategic Directive.

Stephen Pegge
Trustee

Stephen is a career banker and has also been a board director of several institutions with a public interest including the National Centre for Work Experience, the Institute of Small Business Affairs and is a former chair of a charity founded by HRH the Prince of Wales supporting older people into economic activity.

He is part of the senior executive team of UK Finance, the leading financial trade association and leads on commercial finance, sustainability, dispute resolution and international trade. He chairs an advisory group for the UK government on creative industries and is part of a minister led boards on business finance and promoting female and black and ethnic minority entrepreneurship. Stephen is a director of the UK Business Angels Association, the trade association dedicated to promoting angel investing and supporting early-stage investment in the UK. He is also a director of the Business Banking Resolution Service, a voluntary ombudsman scheme for larger SMEs.

Stephen believes Shaw Trust makes a vital contribution and has an even bigger potential role to play in employability, education and support for people to realise their potential whatever their backgrounds over the next few years. He is looking forward to playing his part in supporting it and our clients and hopes his experience and connections can be useful to colleagues and the wider network involved in this vital work.

Kalm Paul-Christian
Trustee

Kalm is an investment banker working in the Financial Institutions Advisory Team at NatWest Markets. There he advises executive management teams to execute strategic and corporate finance decisions for sustainable growth.

He began his career with Rothschild & Co in the Global Financial Advisory division before joining The Social Investment Consultancy where he advised charities, social enterprises, corporates and investment funds on revenue diversification, social business models and impact evaluation.

As an advocate for Social Mobility, Financial Inclusion and Disability Rights, Kalm has been working in the field of accessibility since 2013, delivering projects from DFID, the Commonwealth Youth Council and National Lottery Community Fund.

He is a graduate of the University of Oxford, Fellow of the Royal Society of the Arts and a member of the Worshipful Company of International Bankers. He is also trustee of the Turn2Us and Switchback, a former school governor, and a junior adviser to Chatham House.

Lara Oyesanya
Trustee

Lara joined Shaw Trust in April 2021. Lara is a trustee of Plan International UK and a co-opted Member, Committee on Benefactions, External and Legal Affairs, the University of Cambridge advising the Vice-Chancellor.

The vision of Shaw Trust of a future where good employment is accessible to all in society irrespective of life circumstances resonates with Lara. Growing up in Nigeria, Lara was raised with strong values that included a great sense of social justice, responsibility, accountability, respect, and care for everyone in the community. Shaw Trust’s outlined outcomes for education and skills, children and young people’s services, and health and well-being are areas that Lara believes are essential for a fair and equitable society. This vision is a big draw for Lara as a Shaw Trust trustee and she hopes that the work of Shaw Trust will continue to promote social justice and mobility to address the causes and consequences of poverty in society.

Lara is a solicitor and general counsel in the financial services – digital payments sector, currently General Counsel and Chief Risk Officer at Contis, a contributing editor, LexisNexis Encyclopaedia of Banking Law, and a Consulting Editorial board member LexisPSL©. She is a Fellow of The RSA and ‘Business Woman of the Year’, 2018 FL National Awards. Ranked in The Lawyer Hot 100 2021 and the 50 Must-Follow Black Female Leaders 2020. Formerly, legal director at Klarna, senior legal counsel at Barclays and BAE Systems, a divisional counsel at RAC, a legal director at HBOS, and Group Head of Legal at Lex Autolease. She is a law graduate (LL.B Hons) from the University of Lagos with an LL.M in Comparative Company Law.

Mike Nussbaum
Trustee

Mike joined Shaw Trust in February 2016. Mike sits on the boards of RNIB, Guide Dogs, Vision UK, the Equality and Diversity Forum and supports numerous other charitable organisations.

Mike’s passion for social justice started young when he was involved in a wide range of social action programmes including chairing national youth organisations. Now, following more than 50 years of public service, Mike brings his blind lived experience to Shaw Trust. An active and committed volunteer Mike previously sat on the boards of RNIB, Vision UK, and the Equality and Diversity Forum. Mike is still an active member of the board for Guide Dogs and continues to support numerous other charitable organisations.

Mike is passionate about the added value which volunteers can bring to an organisation as well as the personal benefits of volunteering. Supporting Shaw Trust’s 1,000 person strong volunteer programme, Mike received a national ‘Year of the Volunteer’ Award for services to volunteering in 2005, and in 2008 The Open University awarded him an Honorary Doctorate.

Annamarie Hassall MBE
Trustee

Annemarie was appointed to the Board as a trustee in autumn 2019. An expert in her field, she was appointed MBE for services to children and families in 2011.

At Shaw Trust Annamarie draws on all of her sector experience of working with charity, private sector, local authority and central government to support our work by ensuring we are on the right track, doing what we have agreed, delivering on commitments and doing it well.

Volunteering her time as a trustee it was the values of Shaw Trust that most attracted Annamarie. The belief people should be at the heart of change; employment as a goal for everyone and the focus on skills; valuing education, training and skills for life.

To find out more about Annamarie connect on LinkedIn.

Deborah Dorman
Trustee

Deborah is a highly experienced strategic leader, with a passion for engagement and representation; ensuring everyone has a voice and that they can fulfil their potential.

Deborah is currently the Director of Group HR for Sainsbury’s, with extensive HR experience including strategy, organisational change, talent, learning, reward, inclusion, recruitment and engagement.
Deborah’s recent achievements include leading the design of customer-centric cultural transformation marrying humanity with performance edge, and spearheading the creation of a new inclusion strategy, which improved senior female representation within Sainsbury’s. Deborah has previously been an Advisory Board Member with Business in the Community Race Equality where she led the creation of the Youth Advisory Panel, to give young people a greater voice in improving employment and progression for ethnic minorities. Deborah has a passionate and open style with a focus on inspiring people to create strong relationships and deliver excellent results, whilst maintaining an environment based on professional integrity, transparency, and honesty. Deborah is looking forward to contributing to the important work of Shaw Trust, to support people to live decent and dignified lives. Deborah believes that everyone should have the chance to fulfil their potential and that access to education and employment are vital.

Audrey Coutinho
Trustee

Audrey joins as a Trustee in June 2021. Shaw Trust’s inspiring vision for a future where good, rewarding and dignified employment is accessible to all and the values of the Trust were the primary attractions for wanting to be a Trustee at the organisation.

The Trust’s focus on education and training one of the core enablers for an individual’s success in their lives aligns closely with Audrey’s beliefs, so when the opportunity to be involved in supporting this mission was available it was an easy decision to make.

Audrey has always admired and appreciated the commitment and ethos of the third sector and the critical role it plays in civil society with social justice at the heart of it. Having spent over two decades in the corporate world this as the right time to commit and support the sector and use her skills and experience.

Audrey is an accomplished senior executive with broad experience in designing strategy, delivering digital transformations and complex global programmes that support and serve employees and customers. She brings with her diverse experience in general management, audit and risk management and more recently as Chief Data Officer. She has a Masters’ degree in Business Administration.

Diane Côté
Trustee

Diane holds a number of board roles including at Societe Generale SA and X-Forces Enterprise.

She supports other charitable organisations and is a member of several associations and forums that promote Diversity and Inclusion in the workplace including the Women Network Forum.

Diane had a successful executive career in the UK and in Canada in the financial industry. She has featured in the ‘100 Most Influential Women in European Finance’ for the last six years.

In her last executive role as CRO at London Stock Exchange Group, she chaired the LSEG Foundation was an Executive Committee member and she also launched and championed the gender diversity agenda through the Women Inspired Network and lately the Inclusion Network.

Diane has a passion for helping young people from all backgrounds to be given equal opportunities to build their future, fulfil their potential and to support gender equality and minority representation at senior level in the workplace. Having been part of a minority group at senior level throughout her entire career, she understands the importance of embracing an all-inclusive culture.

Paul Baldwin
Trustee

After two decades working in the banking and finance industry, in 2009 Paul decided he would rather spend his time working on the causes that he is passionate about.

Since then he has pursued a portfolio career working with a select number of charitable organisations across a range of different sectors. His most significant areas of interest include, disability, education and skills, conservation and the environment, and animal protection, including as chair of Battersea Dogs & Cats Home. Paul first became aware of Shaw Trust while he was Chair of the Disabled Living Foundation (DLF) and was looking for a suitable merger partner to secure DLF’s long-term future. An immediate meeting of minds led to a successful merger in 2014, and Paul joined the Shaw Trust board in 2016. Other than working as a charity trustee, Paul is happiest when in the mountains: hiking, ultra-running, skiing, or teaching adaptive snow sports to people with a range of different disabilities.

Olly Benzecry
Chair of Trustees

Olly became our Chair of Trustees in February 2023. He is passionate about helping those with disadvantages to achieve their potential in employment.

In addition to being the Chair of Shaw Trust, Olly is a Trustee of Movement to Work and advises WithYouWithMe, an international provider of skills-based talent management solutions. He is Chair of the Corporate Development Board of the Natural History Museum (NHM) and a member of the Corporate Partnership Board of Cancer Research UK. Olly advises Faculty, a world leading AI provider, as well as being a CEO advisor more broadly.

Previously, Olly was Chair and CEO of Accenture, UK & Ireland

Chris Luck CB MBE DL
Group CEO, Shaw Trust

Chris joined the Trust in May 2019, after a distinguished career in the armed forces.

Chris had not planned to move into the voluntary sector, however, his life experiences, personal values and strong sense of purpose made him the perfect fit to lead Shaw Trust. Ensuring those we support are at the heart of everything we do, Chris has implemented a new organisational structure, reviewed our strategic direction and championed new initiatives, including the Shaw Trust Foundation and Shaw Trust Policy Institute supporting and advocating for social mobility through opportunity.

To find out more about Chris follow him on X or connect on LinkedIn.