This statement sets out the steps taken by Lifetime Group (Lifetime Training, Innovate Awarding and Skilltech Solutions) to prevent modern slavery and human trafficking in its operations and supply chain for the financial year 1 August 2024 to 31 July 2025, in accordance with Section 54 of the Modern Slavery Act 2015.

The use of modern slavery in any form is fundamentally unacceptable. As a leading provider of skills and learning solutions, the Group is committed to acting ethically, assessing risks, and taking all reasonable steps to prevent modern slavery within our organisation and supply chain.

Modern slavery oversight is embedded within the Group’s governance structure, with any concerns escalated to senior leadership, including the CEO and Board. Safeguarding is integral to our learner support model and strengthens our ability to identify and escalate concerns relating to exploitation. Our operations are based solely in the United Kingdom, and although our risk exposure is assessed as low, we remain committed to continuous monitoring and improvement.

Progress Since the Last Statement

Since the publication of the Group’s last statement, modern slavery and ESG & Impact (ESGI) have remained priority areas. The Group has implemented an ESGI governance structure and appointed a Head of ESGI to support ongoing development and oversight of our strategy. Safeguarding training now includes modern slavery awareness, and modern slavery due diligence questions have been added to supplier questionnaires to strengthen accountability across our supply chain.

Organisational Structure and Supply Chains

Lifetime Group is a UK-based provider of skills and learning solutions, comprising of Lifetime Training, Innovate Awarding and Skilltech Solutions. Strong governance underpins our approach to preventing modern slavery, with oversight provided by the Board, ESGI Steering Committee, and ESGI Forum.

The Group delivers training and assessment across sectors including retail, hospitality, early years, health and social care, leadership and management, and digital. Our supply chain includes education and assessment providers, IT and digital services, data hosting partners, professional services, recruitment and marketing providers, and office and facilities suppliers. While exposure to high-risk sectors is limited, we remain committed to robust due diligence and ongoing monitoring.

Relevant Policies

Lifetime Group has several policies that support the identification, prevention, and escalation of modern slavery risks across all Group brands. These policies apply to employees, suppliers, contractors, and third parties working on our behalf. These policies operate collectively to support early risk identification and clear escalation routes.

Code of Conduct: sets expectations for professional behaviour, integrity and compliance with UK law for all employees, contractors, suppliers and third parties working on behalf of the Group, including the duty to report concerns through the Group’s whistleblowing channels.

Whistleblowing Policy: enables concerns from external sources or internal team members to be raised confidentially or anonymously, including through an independent external service, with escalation through governance channels where appropriate.

Resourcing Policy: sets out safer recruitment measures, including right-to-work verification, identity checks and, where required, DBS or BPSS vetting, carried out by accredited third-party providers. Regular audits provide assurance that safer recruitment standards are met.

Lifetime Group is committed to providing multiple safe and confidential routes for raising concerns about suspected modern slavery. Individuals may report concerns to their line manager, the People Team, the Safeguarding Team, or anonymously through the Whistleblowing process.

Policies are embedded through supplier contracting, onboarding and ongoing review, and are reviewed annually to ensure alignment with legal requirements and best practice.

Responsibilities and Due Diligence

Lifetime Group undertakes due diligence across its operations and supply chain to identify and manage modern slavery risks. Oversight sits within the Group’s governance structure, with risks escalating to senior leadership and the Board where required. No instances of modern slavery or human trafficking were identified during the reporting period. Should modern slavery ever be identified, the Group is committed to acting promptly, engaging with appropriate agencies, and supporting responsible remediation.

All new and existing suppliers complete modern slavery due diligence, including a questionnaire aligned with the Modern Slavery Act and review of relevant policies and controls. We engage with suppliers and partners to promote ethical practice and support wider efforts to prevent exploitation.

The Group retains the right to request further information and conduct investigations, with higher-risk suppliers subject to enhanced monitoring. Supplier due diligence outcomes are incorporated into ESGI reporting and reviewed by the Board.

Employees, contractors, and suppliers are expected to complete mandatory modern slavery training, understand this policy and report concerns through established reporting lines, including confidential whistleblowing channels.

Where a supplier fails to meet required standards, or does not remedy issues in a timely manner, the Group may suspend or terminate the relationship. 
Lifetime Group’s safeguarding framework supports risk identification by providing clear reporting routes and specialist case management for learners who may be vulnerable to exploitation. All safeguarding concerns are regularly reviewed and reported to the Board and the Learner Experience Committee, with an annual review of trends to help identify emerging risks and inform continuous improvement.

Lifetime Group expects suppliers, subcontractors and partners to demonstrate inclusive employment practices, undertake appropriate workforce checks, and ensure their own policies prevent the exploitation of vulnerable groups. We recognise that individuals with certain protected characteristics or personal circumstances including disabilities, pregnancy or maternity, age, socio-economic disadvantage, migration status, language barriers or neurodiversity may face increased risk of exploitation. The Group is committed to identifying and addressing these vulnerabilities by ensuring that its recruitment, onboarding, learning provision, working practices and supplier interactions do not place disadvantaged groups at heightened risk.

Risk Assessment

Lifetime Group assesses modern slavery risks across its operations and supply chain. While overall risk is considered low due to our UK-based model, we recognise potential vulnerabilities in certain supplier categories and in sectors where apprentices may be more exposed to exploitation. Our risk assessments also take account of factors that may increase vulnerability among individuals and workforce groups, ensuring appropriate mitigations are applied where needed.

Risks are monitored and reviewed through the Group’s ESGI governance structure and escalated where necessary. Modern slavery considerations form part of the Group’s ESGI Risk and Opportunities Matrix, which evaluates potential risks and informs mitigation measures, including supplier due diligence, safeguarding processes and whistleblowing mechanisms.

Performance Indicators

Lifetime Group monitors the effectiveness of its modern slavery controls through several indicators:

Training and Awareness: All employees are required to read and understand this policy. Modern slavery e-learning has been incorporated into mandatory safeguarding training. 

Supplier Due Diligence: All suppliers must complete modern slavery due diligence and cooperate with requests for information, with outcomes reviewed as part of ESGI reporting.

Supplier Monitoring: Where appropriate, suppliers permit Lifetime Group to conduct or commission compliance checks and audits, with findings monitored through the governance structure.

Risk and Concern Reporting: Concerns raised through safeguarding or whistleblowing channels relating to potential exploitation are reviewed to ensure appropriate escalation and resolution.

These indicators support ongoing monitoring, continuous improvement, and assurance that modern slavery risks are being effectively managed. In the year ahead, the Group will continue to strengthen collaboration with suppliers and enhance due diligence and assessment processes.  

Statement of Commitment

Charlotte Bosworth, Chief Executive Officer
18th December 2025

This statement has been approved by the Board of Directors, the Group’s principal governing body, for the financial year from 1 August 2024 to 31 July 2025. It will be published on the Lifetime Group website, made available to stakeholders and reviewed annually.