Modern Slavery & Huma Trafficking

School of Pan African Studies (the “School”)

Statement period: 1 March 2025 – 28 February 2026

Date approved: 26 February 2026

This Modern Slavery and Human Trafficking Statement (the “Statement”) is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps the School has taken, and continues to take, to prevent modern slavery and human trafficking in its business operations and supply chains.

The School has a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude, and child labour, and is committed to acting ethically and with integrity in all business relationships.

2.1 About the School

The School is an education and professional development organisation delivering world-class online graduate and professional programmes, professional certificates, short courses, research commissions, and policy entrepreneurship initiatives focused on African development, politics, philosophy, and economics.

The School’s educational philosophy is committed to epistemic justice and to centring Africa as the primary ontological base for curriculum design, moving beyond Eurocentric models. The School’s strategic intent includes supporting “brain gain” by enabling the diaspora to contribute to continental development.

2.2 Operational footprint

The School primarily operates through online delivery, remote teaching, and digital learning platforms. The School engages:

Employees, consultants, and associates (including teaching faculty and research collaborators);
Digital and professional service suppliers (e.g., learning platforms, communications tools, cloud services, payment processors, marketing and design services);
Research and content suppliers (e.g., commissioned authors, editors, peer reviewers).

2.3 Supply chains overview

The School’s supply chain is primarily services-based, and typically includes:

Technology and digital services: learning management systems (LMS), hosting, cloud storage, cybersecurity, analytics, and software subscriptions.
Professional services: legal, finance, accounting, HR support, and consultancy.
Content and education services: course content creation, instructional design, editing, transcription/captioning, and academic support.
Marketing and communications: digital marketing, design, content distribution, and event support.
Payments and student services: payment processing and customer support services.

The School maintains and/or implements policies and processes that support the prevention of modern slavery and human trafficking, including:

Code of Conduct / Expected Standards of Behaviour for staff and contractors (including ethical conduct and reporting expectations).
Recruitment and Development practices designed to prevent unfair or exploitative labour practices and ensure transparency in engagement terms.
Safeguarding and Student Welfare policies, recognising that vulnerable individuals may be at increased risk of exploitation.
Whistleblowing arrangements enabling confidential reporting of concerns without retaliation.
Supplier and contracting standards, including appropriate contractual protections and termination rights for material ethical breaches.

Where the School engages workers through contractors or agencies, the School expects suppliers to comply with all applicable employment laws and to prohibit modern slavery and human trafficking in their own operations and supply chains.

4.1 Risk-based approach

The School applies a proportionate, risk-based approach to identifying and managing modern slavery risks, taking into account:

Sector risk (services-based, online education—generally lower prevalence than high-risk sectors, but not risk-free);
Geographic and jurisdictional factors (where suppliers and collaborators are located), including across the African continent and the diaspora;
Nature of the service (e.g., outsourced support services that may involve subcontracting);
Worker vulnerability factors (e.g., low pay, precarious work, high dependency on intermediaries, or limited bargaining power).

In line with the School’s mission of socialist Pan-Africanism and economic justice, the School seeks to ensure that procurement and contracting decisions promote dignified work, fair value distribution, and non-extractive relationships, and that suppliers do not rely on exploitative labour practices.

4.2 Due diligence activities

During the statement period, the School’s due diligence approach has included:

Supplier onboarding checks, appropriate to supplier size and risk profile (e.g., confirming corporate identity, service scope, and contracting entity).
Contracting controls, including clauses requiring compliance with applicable laws and ethical standards and enabling termination for serious misconduct.
Review of labour model used in delivery (employees/contractors/associates), ensuring transparency of terms and payment practices.
Assessment of subcontracting risk where suppliers may outsource elements of delivery (e.g., captioning/transcription, customer support, marketing services).

The School also commits to strengthening due diligence through auditing and assurance over its global supply chains, with a particular focus on:

Ethical procurement of digital services (including LMS, cloud/hosting, cybersecurity, payments, communications tools, analytics, and outsourced support), including transparency of subcontractors and labour standards in service delivery; and
Ethical procurement of research materials and research-related services (including commissioned research inputs, data collection/processing, transcription/translation, editing, and publication/distribution support) sourced across the African continent and the diaspora.

These audits may include (as proportionate to risk): supplier questionnaires and attestations, contractual audit rights, sampling of subcontractor arrangements, review of publicly available compliance disclosures, and targeted follow-up where red flags are identified.

4.3 Internal controls for staff/contractor engagement

The School aims to ensure that:

Engagement terms are documented and clear (scope, rates, payment timelines, IP terms, confidentiality, and standards of conduct);
Payments are made through approved channels with appropriate records;
Right-to-work and identity checks are conducted where required by law and proportionate to the role and location;
No fees are charged to workers for recruitment or placement by or on behalf of the School (and any such practice is treated as a red flag).

Given the School’s profile, the School considers the following to be its most relevant areas of potential risk:

Outsourced digital and creative services where subcontracting can occur (e.g., design, marketing, content editing, transcription/captioning).
International contractor engagements, where local labour protections and enforcement may vary.
Platform-based gig work where individuals may be economically vulnerable or exposed to unfair labour practices by intermediaries.

The School does not tolerate any use of forced labour, debt bondage, or withholding of identity documents and will take action if concerns are identified.

The School is committed to ensuring that relevant personnel understand modern slavery risks and indicators, and know how to raise concerns. During the statement period, the School has prioritised:

Management awareness of modern slavery indicators and reporting routes;
Procurement/contracting awareness proportionate to the School’s size and supplier profile.

The School intends to expand training coverage for those responsible for supplier onboarding and contractor management.

7.1 Raising concerns

Concerns about modern slavery or human trafficking relating to the School’s operations or supply chains may be reported through the School’s internal reporting channels or by contacting the School via its published contact routes on panafricanthought.com. Reports may be made confidentially and, where possible, anonymously.

7.2 Non-retaliation

The School will not tolerate retaliation against anyone who raises concerns in good faith.

7.3 Response and remediation

Where a concern is raised, the School will:

Assess the allegation promptly and proportionately;
Engage with the relevant supplier/party to investigate;
Require corrective actions and evidence of remediation where appropriate;
Consider suspension or termination of contracts where remediation is not satisfactory or where severe breaches are identified; and
Where appropriate, report to relevant authorities.

The School is developing proportionate measures to assess the effectiveness of its approach to modern slavery risk management. The School’s current and planned measures include:

Tracking the number of suppliers/contractors assessed for modern slavery risk during onboarding;
Tracking contractual inclusion of modern slavery / ethical compliance clauses;
Recording and reviewing any reported concerns, responses, and outcomes;
Periodic review of high-risk supplier categories and subcontracting practices.

During the next statement period, the School intends to:

Implement a concise Supplier Ethical Standards document referencing modern slavery expectations and the School’s mission of socialist Pan-Africanism and economic justice;
Introduce a risk-tiered onboarding questionnaire for suppliers in higher-risk categories (including subcontracting transparency);
Formalise a light-touch annual review process for key suppliers;
Provide targeted training/briefing for personnel responsible for procurement and contractor engagement;
Implement a proportionate audit programme for global supply chains, prioritising (i) digital services and (ii) research materials and research-related services sourced across the African continent and the diaspora, and requiring remediation plans where issues are identified.

This Statement has been approved by the School’s leadership.

Approved on: 26 February 2026

Nigel Stewart Co-Founder, School of Pan African Studies