Modern Slavery and Human Trafficking Policy Statement

Our Commitment

I, Dr Dave Wood, as the sole proprietor of Metanoeo, am committed to acting ethically and with integrity in all business dealings and relationships. I will implement and enforce systems and controls to ensure modern slavery and human trafficking are not taking place in my business or in any part of my limited supply chains.

This policy applies to me as the sole trader, any subcontractors (e.g., occasional trainers or virtual assistants), and all third-party suppliers, clients, and trainees.

Modern Slavery Risk Assessment

Given the nature of the business—providing professional services (life coaching and coach training) typically to professional adults in the UK—the risk of modern slavery existing within the direct operation is low.

However, the risk must be considered in the context of the supply chain, which includes:

• Administrative Services: Virtual assistants, IT support, software providers.
• Rented Venues: Hotels or conference centres used for training (if applicable).
• Physical Goods: Office supplies, printing materials (if applicable).

I maintain a zero-tolerance approach to modern slavery and human trafficking.

Due Diligence and Contracting

Personnel and Subcontractors

• Self-Employed Status: I operate solely as a self-employed individual. All hours are self-directed, and remuneration is transparently defined through invoices and payments.
• Subcontractors/Assistants: Any individual engaged on a freelance or short-term basis (e.g., virtual assistants, guest speakers) will be contracted directly. I will ensure they are paid the agreed-upon rate, meet the UK minimum legal working age, and are responsible for their own employment rights and taxes.

Supply Chains (Venues and Goods)

• Venue/Hotel Use: When contracting with larger organisations for venue hire (e.g., hotels for a training course), I will aim to confirm that the supplier has their own Modern Slavery Statement or policy in place (required for large UK companies).
• Procurement: When purchasing IT equipment, furniture, or professional services, I will prioritise established UK suppliers known for ethical supply chains.
  

Training and Awareness

As a sole trader, I am responsible for my own awareness. I will:

• Ensure I am familiar with the signs of modern slavery and human trafficking.
• Maintain awareness of the Modern Slavery Act 2015 and its relevance to UK businesses, regardless of size.
• Ensure any formal training materials I deliver do not inadvertently contain or use materials/goods produced under conditions of exploitation.

Reporting and Enforcement

Reporting Procedure

If I suspect or become aware of any instance of modern slavery or human trafficking linked to my business or my supply chain, I will take immediate action:

• Immediate Threat: If a person is in immediate danger, call the Police on 999.
• Report to Authorities: For non-urgent concerns, I will report the situation to the relevant authority, such as:
  • The Modern Slavery Helpline: 08000 121 700
  • The Police (via 101 for non-emergencies).
  • The Local Authority Social Services (if the victim is a child or an adult at risk)
• Sever Relationships: I will immediately cease all business relationships with any supplier or subcontractor found to be in breach of this policy.
  

Policy Review

This policy will be reviewed and updated annually or whenever there are significant changes to the business model or supply chain to ensure continued compliance and ethical operation.