Modern Slavery Act


Mind Gym plc (‘Mind Gym’) is committed to ensuring that slavery and human trafficking is not taking place in our business or in our supply chain. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Mind Gym’s slavery and human trafficking statement for the financial year ending 2019. This statement outlines the steps that Mind Gym has taken and is taking to ensure slavery or human trafficking is not taking place in any part of our business or in our supply chains.

Organisation's structure

We are a global provider of behavioural science in the Learning & Development sector. Mind Gym plc is the parent company of wholly owned subsidiary companies in the USA and Singapore (the “Group”). The Group has over 223 employees over 4 offices, in London, New York, Houston and Singapore and operates in up to 69 countries.

Our business

Mind Gym’s business model provides for separate teams for sales, creative, workshop delivery and programme management, located primarily in London and New York. Our creative team consists of freelance creatives as well as employees. Workshops are delivered by some 276 freelance qualified coaches, locally based in over 30 countries.

Our policies and training

Mind Gym has a global policy on modern slavery which states we oppose all forms of slavery or human trafficking and we are committed to taking steps to ensure these do not occur in our business. Our modern slavery policy is one of several policies that reflect our commitment to acting with integrity in all our business relationships.

We are committed to ensure our personnel have a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. Our managers and others responsible for procurement are trained on the Modern Slavery Policy and all staff are advised of the range of policies we have implemented.

Other policies include an equal opportunities policy, a harassment and bullying policy, an anti-bribery and corruption policy and a whistleblowing policy or their local equivalents. Our whistle-blowing policy, (or local equivalent) provides a detailed internal mechanism for reporting concerns in the strictest confidence without fear of disciplinary action.

Our supply chains and due diligence processes

In addition to our freelance coaches and creatives, our supply chains include a range of indirect support services, (for example IT, printing services, professional advisers) providing goods and services to support the services we in turn provide to our clients. Suppliers are managed by the relevant business function. Some are engaged on a global scale, whereas others are managed at a local level.

We recognise that modern slavery and human trafficking may occur in countries from which we procure goods and services. We are committed to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We are taking steps to identify and assess potential risk and to mitigate and monitor potential risks in our supply chains.

Procurement Processes

Our main aim is to ensure we engage with suppliers that have similar approach to values and ethics and to ensure we implement measures to gauge how effective we have been to ensure that slavery and human trafficking has not taken place in our business and supply chains.

Key Progress

We keep our procurement processes under review and the following steps have been taken:

  • We have prepared a supplier questionnaire which references issues such as Modern Slavery.
  • We have implemented processes to ensure our supplier contracts are reviewed and in high risk areas have appropriate provisions.
  • We have a whistleblowing policy (or its local equivalent) to protect whistle blowers.
  • We have implemented processes within the relevant business teams to ensure new suppliers complete the questionnaire.

Building on the steps taken to date, we have identified the following specific enhancements for the next financial year and beyond:

  • We are forming a dedicated compliance team, which consists of involvement of the legal, , IT, and HR teams.
  • We are creating a supplier framework to determine our key suppliers, whether the relationship is ongoing and to implement an annual review.
  • We are preparing a supplier code to which suppliers will be asked to sign up and which addresses issues such as Modern Slavery, corruption and diversity in particular in high risk areas.
  • We are devising methods to carry out reasonable and practical checks to test whether our standards are being implemented throughout our suppliers’ businesses.
  • We are committed to asking our business partners to provide training to their staff and suppliers and providers.
  • We are looking to secure an approach that we can use to measure how effective it has been to ensure that slavery and human trafficking has not taken place in its business and supply chains.
  • We are conducting a risk review process in relation to all our offices and local suppliers to determine our risk and incidents of modern slavery and whether further due diligence is necessary.
  • We are carrying out a risk assessment on our top suppliers globally to assess what measures need to be implements to compliment those that are already in place.

Ongoing commitment

The Group’s policies and procedures are subject to an annual review and where required they will be updated. The Group’s employees and contractors will receive appropriate training to ensure such updated policies and procedures are explained and understood by them.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31st March 2019.

This statement has been approved by the Board of Directors.

Joanne Cash: Board Chair March 2020