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Modern Slavery and Human Trafficking Statement

Modern Slavery and Human Trafficking Statement for the Financial Year ending 31 August 2025

This statement has been published in accordance with the Modern Slavery Act 2015 (“the Act”). It sets out the steps taken by BPP Holdings Limited and its group of companies during the financial year ending 31 August 2025, to prevent modern slavery and human trafficking in its business and supply chains.

Who are we?

BPP Holdings Limited is the parent company of the companies listed in this statement. This statement covers the steps taken by BPP Holdings Limited and its following subsidiary companies: BPP University Limited, BPP Professional Education Limited, BPP Learning Media Limited, Actuarial Education Company Limited, BPP Actuarial Education Limited, BPP Services Limited; BPP International Limited; Estio Training Limited, Firebrand Training Limited and Buttercups Training Limited (“BPP”).

Although not all the companies listed above meet the reporting threshold under the Act, BPP is committed to ensuring that all its businesses meet BPP’s commitment to ethical business practices.  Accordingly, all listed BPP companies meet the standards set out in this statement.

Our Business

BPP provides higher education, professional education, apprenticeships and learning materials to a global community of students and clients.

 Details of our core business operations, per company can be found below:

  1. BPP University Limited offers degree, post graduate and apprenticeship education across its four schools: BPP University Law School, BPP University Business School, BPP University School of Technology and BPP University School of Healthcare and Nursing.

  2. BPP Professional Education Limited offers professional qualifications, professional development, and apprenticeship education in several areas including accountancy, people and skills development, tax, and HR.

  3. BPP Learning Media Limited provides learning materials and resources (in a wide choice of formats) across a broad range of vocational qualifications.

  4. BPP Actuarial Education Limited and Actuarial Education Company Limited offer actuarial education and study materials.

  5. Estio Training Limited offers digital and technology apprenticeship education.

  6. Firebrand Training Limited offers a wide range of IT certifications together with IT and digital apprenticeship education.

  7. Buttercups Training Limited offers pharmacy apprenticeships and training.

Our Commitment

BPP has zero tolerance to modern slavery or human trafficking.  BPP is committed to and supports international efforts to promote ethical business practices and policies related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking. In our Code of Business Ethics ("the Code"), we acknowledge responsibility under the Act and will endeavour to ensure that slavery and human trafficking are not taking place within our workforce, our business and supply chain and/or our international group companies. 

Managing the risk of modern slavery is also an integral part of BPP’s environmental, social and governance and sustainability initiatives.  Furthermore, BPP is an accredited Living Wage Employer meaning we voluntarily choose to pay the real Living Wage to all directly employed staff, freelancers and temporary staff.

Anti-Slavery and Human Trafficking Policy

BPP operates an Anti-Slavery and Human Trafficking Policy (the “Policy”) which applies to all individuals working for or on behalf of BPP.  The Policy sets out BPP’s responsibilities (and the responsibilities of those working for and on behalf of BPP) in observing and upholding our position on preventing modern slavery. It reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in our supply chains.  The Policy also provides guidance on how BPP personnel (including BPP agents, freelancers, contractors, intermediaries, partners, service providers and any other person who might be perceived as acting on behalf of or for the benefit of any BPP company) can confidentially report concerns about any issue or suspicion of modern slavery.   

Supplier Due Diligence

BPP recognises the importance of operating ethically, with integrity and in compliance with all applicable laws.  Therefore, all BPP suppliers are required to undergo due diligence checks as part of their onboarding to ensure compliance with our values.  This due diligence process enables BPP to assess potential risk in BPP’s supply chain including a modern slavery risk assessment.  All suppliers must repeat this risk assessment at least every 2 years to continue providing goods or services to BPP.

In addition to the due diligence process, our standard supplier contract includes obligations for suppliers to comply with the Act and adhere to BPP’s Code of Conduct. Any breach of these principles, or the Act, will result in the immediate termination of the supplier relationship.    

Examples of BPP’s supply chain include: IT Suppliers; printers (and associated couriers of learning materials); property maintenance providers; student recruitment agents; and consultants (for various education services).  This list is not exhaustive.

Risk Assessment and Management

BPP assesses the areas of its business and supply chain where the risk of modern slavery and human trafficking is most likely to arise. As a UK based education provider, BPP considers its directly employed workforce to be low risk given its recruitment, right-to-work and Living Wage practices. BPP recognises that a higher potential risk sits within certain outsourced parts of its supply chain, and therefore ensures regular due diligence is carried out to minimise risk in these parts of its supply chain.

BPP undertakes risk assessments to identify and mitigate the risk of modern slavery and human trafficking across its supply chains. BPP's supply chain risk assessment considers the following categories: (i) the country of origin of goods and services; (ii) the sector and industry of the supplier; (iii) the nature of the workforce engaged by the supplier, including the use of temporary, agency or migrant labour; and (iv) the complexity and transparency of the supply chain. Where a higher risk is identified, BPP implements enhanced due diligence measures, including additional contractual safeguards and ongoing monitoring.

Whistleblowing Policy

We operate a Whistleblowing Policy, aimed principally at our employees but also available to our suppliers, clients, and learners that encourages the reporting of any wrongdoing within BPP.  This extends to human rights violations like modern slavery. All reports are fully investigated by BPP’s internal Compliance Team, and appropriate remedial actions taken. Metrics relating to whistleblowing activity are internally reviewed.

Learner Safeguarding

The safety and wellbeing of our learners is a priority for BPP. Any prospective or current learner may contact BPP's Safeguarding Team using Safeguarding@bpp.com at any time if they have concerns about exploitation, including any concern relating to modern slavery or human trafficking.

Training

BPP provides training to all new employees on the values included in its Code and receives acknowledgement of the Code from its freelancers and suppliers.  In addition, all BPP staff have access to and are governed by the Policy and receive annual refresher training on the Act. 

Effectiveness

As at the date of this statement, we can confirm that there have been no incidents of human trafficking or modern slavery within BPP or its supply chain.

BPP measures the effectiveness of its approach through a range of indicators, including supplier due diligence completion rates, staff completion of annual modern slavery training, and the volume and outcome of any concerns raised through its whistleblowing and safeguarding channels.

Approval

This statement is made pursuant to section 54(1) of the Act and constitutes BPP’s slavery and human trafficking statement for the financial year ending 31st August 2025. This statement has been approved by the Chief Executive Officer of BPP Holdings Limited.

Graham Gaddes
Chief Executive Officer
Approved and signed on 5th July 2026