The Next Education Consultancy Pvt. Ltd.
Effective Date: May 8, 2025
Next Review Date: May 7, 2026
Published at: www.thenext.edu.np/modern-slavery-policy
Purpose and Commitment
The Next Education Consultancy Pvt. Ltd. (“The Next”) is resolutely committed to preventing and addressing all forms of modern slavery, including slavery, servitude, forced and compulsory labor, human trafficking, forced marriage, debt bondage, and child labor. We acknowledge that modern slavery is a severe violation of fundamental human rights and a global problem demanding constant vigilance and proactive measures. As a responsible organization operating within Nepal and internationally, The Next is dedicated to upholding the highest standards of ethical conduct, human rights, and labor practices. This commitment extends to all facets of our operations, encompassing recruitment, relationships with educational partners, and supply chains. We are dedicated to ensuring that our activities do not directly or indirectly contribute to, or are linked to, modern slavery. This policy articulates our strategy for identifying, preventing, and mitigating the risks of modern slavery and demonstrates our steadfast commitment to:
- Respecting human rights
- Promoting ethical labor practices
- Operating with transparency and integrity
This policy is aligned with and reinforces the principles and provisions of the following international and national legal frameworks:
- The Commonwealth Modern Slavery Act 2018 (Australia)
- The UK Modern Slavery Act 2015
- The Nepal Human Trafficking and Transportation (Control) Act, 2064 (2007)
- The International Labour Organization (ILO) Conventions, including:
- ILO Convention No. 29 (Forced Labour Convention, 1930)
- ILO Convention No. 105 (Abolition of Forced Labour Convention, 1957)
- ILO Convention No. 138 (Minimum Age Convention, 1973)
- ILO Convention No. 182 (Worst Forms of Child Labour Convention, 1999)
- The UN Universal Declaration of Human Rights
- The UN Guiding Principles on Business and Human Rights
Scope
This policy applies to all individuals and entities associated with The Next, including, but not limited to:
- All employees, regardless of their employment status (permanent, temporary, part-time, or contract).
- All contractors, subcontractors, and consultants.
- All vendors, suppliers, agents, and service providers.
- All partner institutions, including educational institutions and organizations with whom we collaborate.
- All students, and any individuals receiving services or support facilitated by The Next.
- Any other person or entity acting for or on behalf of The Next.
Definitions
To ensure clarity and consistent understanding, the following definitions apply within this policy:
Modern Slavery: Encompasses a range of exploitative practices, including:
- Slavery: The status or condition of a person over whom any or all of the powers attaching to the right of ownership are exercised.
- Servitude: The obligation to provide service that is imposed by the use of coercion.
- Forced Labor: All work or service that is exacted from any person under the menace of any penalty and for which the person has not offered himself or herself voluntarily.
- Debt Bondage (or Bonded Labor): The pledging of a person’s services as security for the repayment of a debt, where the value of the services as reasonably assessed is not applied towards the liquidation of the debt, or the length and nature of those services are not limited and defined.
- Human Trafficking: The recruitment, transportation, transfer, harboring, or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation. Exploitation shall include, at a minimum, the exploitation of the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery or practices similar to slavery, servitude or the removal of organs.
- Forced Marriage: A marriage in which one or both of the parties have not freely and fully consented.
- Child Labor: The employment of children in any work that by its nature or the circumstances in which it is carried out, constitutes a threat to their health, safety, or morals. Any work that interferes with a child’s education or is otherwise harmful to their development. The definition of a child is any person under the age of 18, in line with the UN Convention on the Rights of the Child, and relevant ILO conventions.
Governance and Responsibility
The Next recognizes that combating modern slavery necessitates a robust governance structure and clearly defined responsibilities. The following framework outlines the key roles and responsibilities within our organization:
Board of Directors
The Board of Directors of The Next holds ultimate responsibility for the oversight and implementation of this policy.
- The Board will ensure that adequate resources are allocated to prevent and address modern slavery risks.
- The Board will regularly review the effectiveness of this policy and the organization’s efforts to combat modern slavery.
Chief Executive Officer (CEO)
The CEO is responsible for the overall strategic direction of The Next’s efforts to prevent modern slavery.
- The CEO will ensure that the principles of this policy are deeply ingrained in the organization’s culture and operations.
- The CEO will champion a culture of ethical conduct and compliance throughout the organization.
Modern Slavery Compliance Officer (MSCO)
The Next will appoint a designated Modern Slavery Compliance Officer (MSCO) who will be responsible for:
- Developing, implementing, and maintaining this policy and related procedures.
- Conducting comprehensive due diligence assessments to identify and evaluate modern slavery risks across our operations and supply chains.
- Overseeing investigations into any allegations or suspicions of modern slavery.
- Establishing and managing confidential reporting channels for employees, contractors, and other stakeholders to raise concerns.
- Monitoring legal and regulatory developments related to modern slavery and ensuring the organization’s compliance.
- Providing regular reports to the Board of Directors and CEO on the organization’s progress in preventing and addressing modern slavery.
- Coordinating training and awareness-raising activities for staff, partners, and suppliers.
- Serving as the primary point of contact for external stakeholders on matters related to modern slavery.
Departmental Responsibilities
Specific departments within The Next will have the following responsibilities in relation to this policy:
Human Resources (HR):
- Ensure that all recruitment processes are fair, ethical, and comply with all applicable labor laws and regulations.
- Conduct thorough pre-employment checks to verify the identity and legal right to work of all employees.
- Develop and deliver training programs for employees on modern slavery awareness and prevention.
- Ensure that employee contracts comply with all relevant legal requirements and provide fair terms and conditions of employment.
- Maintain accurate and complete employee records.
Procurement/Supply Chain Management:
- Develop and implement a robust supplier due diligence process to assess the risk of modern slavery in our supply chains.
- Incorporate modern slavery clauses into contracts with suppliers, requiring them to comply with this policy and all applicable laws.
- Regularly monitor and audit suppliers to ensure their compliance with this policy.
- Prioritize working with suppliers who demonstrate a commitment to ethical labor practices and human rights.
Operations/Student Welfare:
- Conduct regular site visits and welfare checks to ensure the safety and well-being of students and individuals receiving services.
- Ensure that any accommodation or services provided to students or individuals meet acceptable standards and do not expose them to the risk of exploitation.
- Develop procedures for identifying and responding to potential cases of exploitation or modern slavery affecting students.
- Liaise with relevant authorities and support organizations to provide assistance to victims of modern slavery.
Legal:
- Ensure the organization’s compliance with all applicable laws and regulations related to modern slavery.
- Provide advice and guidance on legal issues related to this policy.
- Review and update contracts and agreements to ensure they comply with modern slavery legislation.
Risk Assessment and Due Diligence
The Next is committed to proactively identifying, assessing, and mitigating the risks of modern slavery associated with our operations and supply chains. We will implement a risk-based approach to due diligence, focusing our efforts on areas where the risk of modern slavery is highest.
Risk Identification
The Next has identified the following areas as potentially posing a higher risk of modern slavery:
High-Risk Operations:
- Use of third-party recruitment agencies, particularly those involved in cross-border recruitment.
- Partnerships with accommodation providers, transportation companies, and visa agents, especially where there is a risk of exploitation of migrant workers or students.
- Situations where students are involved in internships, work placements, or part-time employment, as they may be vulnerable to exploitation.
Geographic Risks:
- Operations or partnerships in regions with a known prevalence of modern slavery, including certain areas within Nepal, and countries with weak labor protections.
- Cross-border migration of individuals for education or work, which can increase vulnerability to trafficking and exploitation.
Sector Risks:
- We acknowledge that certain sectors globally and within Nepal, such as domestic work, construction, hospitality, and agriculture, have higher risks of modern slavery, and we will be vigilant in our dealings with these sectors.
Supplier and Partner Vetting
The Next will implement a comprehensive due diligence process for all suppliers, vendors, and partner institutions, including:
- Risk Assessment Questionnaire: Requiring all new and existing suppliers and partners to complete a detailed questionnaire to assess their understanding of and compliance with modern slavery laws and ethical labor practices.
- Contractual Obligations: Incorporating specific clauses into contracts that:
- Prohibit the use of modern slavery.
- Require compliance with this policy and all applicable laws.
- Grant The Next the right to audit suppliers and partners to ensure compliance.
- Require suppliers and partners to flow down these requirements to their own suppliers and subcontractors.
- Verification and Audits: Conducting audits of suppliers and partners, particularly those in high-risk sectors or locations, to verify their compliance with this policy. These audits may be conducted by The Next or by independent third-party auditors.
- Information Gathering: Gathering and reviewing information from various sources, including:
- Supplier self-assessments
- Independent audit reports
- Industry certifications
- Information from NGOs and other organizations working on modern slavery issues
- Publicly available information
Ongoing Monitoring
The Next will continuously monitor the risk of modern slavery in our operations and supply chains through:
- Regular Audits: Conducting internal audits at least annually to assess compliance with this policy and identify any areas for improvement. External, independent audits will be conducted periodically, with the frequency determined based on risk assessments.
- Performance Indicators: Tracking key performance indicators (KPIs) related to modern slavery, such as:
- The percentage of suppliers and partners who have completed the risk assessment questionnaire.
- The number of supplier audits conducted.
- The percentage of staff who have received training on modern slavery.
- The number of reports received through the whistleblowing mechanism.
- The time taken to investigate and resolve reported concerns.
- Review of Policies and Procedures: Regularly reviewing and updating our policies and procedures to ensure they remain effective and reflect best practices.
- Stakeholder Engagement: Engaging with stakeholders, including employees, students, suppliers, NGOs, and government agencies, to gather feedback and improve our approach to addressing modern slavery.
- Continuous Improvement: We are committed to a process of continuous improvement, regularly evaluating the effectiveness of our measures and seeking ways to enhance our efforts to combat modern slavery.
Training and Capacity Building
The Next recognizes that raising awareness and providing training are crucial to preventing modern slavery. We are committed to ensuring that all individuals associated with our organization understand the risks of modern slavery and their responsibilities in preventing it.
Staff Training
- Mandatory Training: All employees will receive mandatory training on modern slavery upon joining The Next and annually thereafter.
- Training Content: The training will cover:
- The definition of modern slavery and its various forms.
- The relevant laws and regulations, including the Modern Slavery Acts and relevant ILO conventions.
- The risks of modern slavery in our operations and supply chains.
- How to identify potential signs of modern slavery.
- The steps to take if they suspect or become aware of a case of modern slavery.
- The organization’s policies and procedures related to modern slavery.
- The importance of reporting concerns and the available reporting channels.
- The protection available to whistleblowers.
- Tailored Training: Employees in specific roles or departments that are considered to be at higher risk (e.g., HR, procurement, operations) will receive additional, tailored training that is relevant to their responsibilities. This may include training on conducting due diligence, identifying high-risk suppliers, and managing recruitment processes.
- Record Keeping: We will maintain records of all staff training, including the dates, content, and attendees.
- Accessibility: Training materials will be provided in accessible formats and, where appropriate, in multiple languages.
Agent and Partner Awareness
The Next will ensure that all agents, suppliers, and partner institutions are aware of our commitment to preventing modern slavery and understand their responsibilities in this regard. This will be achieved through:
- Policy Dissemination: Providing all agents, suppliers, and partners with a copy of this policy and ensuring they understand its requirements.
- Orientation and Briefings: Conducting orientation sessions or briefings for agents and partners to explain our expectations and provide guidance on recognizing and addressing modern slavery risks.
- Ethical Conduct Declarations: Requiring agents and partners to sign an annual declaration confirming their commitment to ethical conduct and compliance with this policy and all applicable laws.
- Contractual Obligations: Incorporating clauses into contracts with agents and partners that require them to:
- Comply with this policy and all applicable laws.
- Ensure that their own employees and subcontractors are aware of and comply with this policy.
- Cooperate with The Next in any audits or investigations related to modern slavery.
Student Induction and Awareness
The Next is committed to protecting the welfare of students and ensuring they are not vulnerable to exploitation. We will:
- Induction Programs: Include information on students’ rights, safe work practices, and how to seek help in cases of exploitation in our student induction programs.
- Awareness Modules: Develop and provide awareness modules or materials to students on:
- The risks of modern slavery and human trafficking.
- Recognizing signs of exploitation.
- Available support services and reporting mechanisms.
- Safe accommodation and employment practices.
- Visa and Immigration Support: Provide clear and accurate information to students on visa requirements and immigration procedures to reduce their vulnerability to exploitation by unscrupulous agents or employers.
- Monitoring Student Welfare: Implement procedures for monitoring the welfare of students, particularly those in work placements or internships, and for responding to any concerns about their safety or well-being.
- Collaboration: Collaborate with educational institutions, government agencies, and NGOs to provide support and resources to students who may be at risk of or have experienced exploitation.
Reporting and Whistleblowing
The Next is committed to creating a culture of openness and accountability, where individuals feel safe to raise concerns about potential violations of this policy without fear of retaliation. We will maintain confidential and accessible reporting channels and ensure that all reports are thoroughly investigated.
Reporting Channels
The following reporting channels are available to employees, contractors, students, and other stakeholders:
- Open Door Policy: The Next maintains an open-door policy. Any and all individuals are encouraged to report concerns related to compliance with this policy and modern slavery, directly to their supervisor, HR department, or the Modern Slavery Compliance Officer.
- Online Reporting Form: A secure online form on the company website (www.thenext.edu.np/modern-slavery-policy) that can be used to submit reports.
All reporting channels will be accessible, confidential, and available in appropriate languages.
Investigation and Escalation
The Next will ensure that all reports of suspected modern slavery are taken seriously and investigated promptly and thoroughly. The following procedures will be followed:
- Initial Assessment: All reports will be assessed within 24 hours of receipt to determine the appropriate course of action.
- Investigation: A thorough and impartial investigation will be conducted by the MSCO or a designated investigator, with the appropriate level of expertise. Investigations will be conducted in a sensitive and confidential manner, protecting the rights of all parties involved.
- Documentation: All reports, investigation findings, and outcomes will be documented in a confidential and secure manner.
- Escalation: Serious or complex cases will be escalated to the CEO and/or the Board of Directors, as appropriate.
- Corrective Action: If the investigation reveals a violation of this policy or any applicable laws, The Next will take appropriate corrective action.
- Timeliness: Investigations will be initiated within 48 hours of receiving a report, and The Next will strive to complete investigations as quickly as possible, while ensuring thoroughness and fairness.
- Communication: The Next will communicate the outcome of investigations to the reporting person, where appropriate and permitted by law, and to any affected parties.
Whistleblower Protection
The Next is committed to protecting individuals who report concerns about potential violations of this policy.
- Non-Retaliation: No employee, contractor, student, or other person will suffer any adverse consequences as a result of reporting a concern in good faith. Retaliation of any kind is strictly prohibited and will be dealt with appropriately.
- Confidentiality: All reports will be treated confidentially, and the identity of the reporting person will be protected to the fullest extent possible, consistent with the need to conduct a thorough investigation and comply with legal obligations.
- Legal Protection: The Next will comply with all applicable laws and regulations related to whistleblower protection, including the provisions of the Nepal Human Trafficking and Transportation (Control) Act, 2064 (2007) and any other relevant legislation.
- Support: The Next will provide support and assistance to individuals who report concerns, as needed, including access to counseling or legal advice.
Victim Support Framework
The Next recognizes that individuals who have been subjected to modern slavery require specialized support and assistance. We are committed to ensuring that any victims identified in connection with our operations or supply chains receive appropriate care and protection.
Immediate Assistance
In cases where a potential victim of modern slavery is identified, The Next will take immediate steps to ensure their safety and well-being, including:
- Safety and Security: Ensuring the immediate safety and security of the individual.
- Referral to Support Services: Referring the individual to appropriate support services, including:
- Specialized NGOs that provide support to victims of trafficking and modern slavery.
- Legal aid organizations.
- Medical and psychological counseling services.
- Safe accommodation and shelter.
- Liaison with Authorities: Cooperating fully with law enforcement authorities in any investigations related to modern slavery.
- Emergency Assistance: Providing or facilitating access to emergency assistance, such as food, clothing, and medical care.
Support for Students
In cases where a student is identified as a potential victim of modern slavery, The Next will take additional steps to provide specialized support:
- Emergency Relocation: Arranging for emergency relocation from exploitative housing or work situations.
- Visa and Immigration Assistance: Liaising with relevant embassies or immigration authorities to provide assistance with visa or immigration issues, if required.
- Educational Support: Providing support to enable the student to continue their education, if desired, and to minimize any disruption to their studies.
- Long-Term Support: Working with support organizations to ensure the student receives appropriate long-term support, including counseling, legal assistance, and reintegration services.
Monitoring, Audits, and Continuous Improvement
The Next is committed to continuously monitoring the effectiveness of this policy and our efforts to prevent and address modern slavery. We will implement a system of regular audits and reviews to identify areas for improvement and ensure that our approach remains robust and effective.
Performance Indicators
The Next will track the following key performance indicators (KPIs) to measure the effectiveness of our efforts to combat modern slavery:
- Percentage of suppliers and partners screened and audited annually.
- Percentage of staff trained on modern slavery, and the effectiveness of the training as measured by post-training assessments.
- Number of reports received through the reporting channels, and the nature of those reports.
- Timeliness and effectiveness of investigations into reported concerns.
- Outcomes of investigations, including any corrective actions taken.
- Number of victims of modern slavery identified, and the support provided to them.
- Improvements made to policies and procedures based on audit findings and stakeholder feedback.
Annual Audit and Review
The Next will conduct regular audits and reviews to assess our compliance with this policy and identify any areas for improvement:
- Internal Audit: An internal audit will be conducted at least annually to assess the implementation and effectiveness of this policy.
- External Audit: Independent third-party audits will be conducted periodically, with the frequency determined based on risk assessments.
- Management Review: The MSCO will provide regular reports to the CEO and Board of Directors on the implementation and effectiveness of this policy.
- Policy Review: This policy will be reviewed at least annually and updated as needed to reflect changes in laws, regulations, or best practices.
- Stakeholder Feedback: The Next values feedback from our stakeholders and will actively seek their input to improve our approach to addressing modern slavery. We will:
- Consult with Stakeholders: Consult with employees, students, suppliers, NGOs, and other relevant stakeholders to gather their feedback on this policy and its implementation.
- Feedback Mechanisms: Establish mechanisms for stakeholders to provide feedback, such as surveys, meetings, and online platforms.
- Transparency: Be transparent about how stakeholder feedback is used to inform our policies and practices.
- Collaboration: Collaborate with stakeholders on initiatives to prevent and address modern slavery.
Public Reporting and Transparency
The Next is committed to transparency in our efforts to combat modern slavery. We will publish an annual Modern Slavery Statement that provides information about the steps we have taken to identify and address the risks of modern slavery in our operations and supply chains. The annual statement will be published on our website at www.thenext.edu.np/modern-slavery-policy and will include information on:
- The structure of our organization and our supply chains.
- Our policies and procedures related to modern slavery.
- The risks of modern slavery that we have identified in our operations and supply chains.
- The steps we have taken to assess and address those risks.
- The effectiveness of the measures we have taken.
- Our plans for further action to prevent and address modern slavery.
- Key performance indicators related to our efforts to combat modern slavery.
- Where possible, a list of our key suppliers and the findings of any audits conducted.
- Case studies or examples of how we have addressed modern slavery risks.
Compliance with Data Privacy
The Next is committed to protecting the privacy of all individuals involved in the implementation of this policy, including those who report concerns, potential victims of modern slavery, and suppliers and partners.
- Data Handling: All personal data will be collected, used, and stored in accordance with the Nepal Privacy Guidelines and the General Data Protection Regulation (GDPR), where applicable.
- Consent: Personal data will only be shared with third parties with the explicit consent of the individual, unless required by law.
- Data Minimization: We will only collect the personal data that is necessary for the purposes of implementing this policy and complying with legal obligations.
- Data Security: We will implement appropriate technical and organizational measures to protect personal data from unauthorized access, use, or disclosure.
- Data Retention: Personal data will be retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by law.
- Breach Notification: Any data breach that is likely to result in a high risk to the rights and freedoms of individuals will be reported to the relevant supervisory authority within 72 hours of becoming aware of the breach, where required by law.
- Training: Staff involved in the handling of personal data will receive regular training on data protection principles and procedures.
Policy Review and Updates
The Next is committed to ensuring that this policy remains effective and up-to-date. We will review and update this policy at least annually, or more frequently if necessary, to:
- Reflect changes in local or international laws and regulations.
- Incorporate best practices and guidance on modern slavery prevention.
- Address any gaps or weaknesses identified through audits, investigations, or stakeholder feedback.
- Improve the effectiveness of our efforts to combat modern slavery.
- Ensure ongoing suitability.
Any updates to this policy will be communicated to all relevant stakeholders, including employees, suppliers, and partners. The updated policy will be published on our website.
Contact Information
The Modern Slavery Compliance Officer (MSCO) is the primary point of contact for any questions or concerns related to this policy.
Modern Slavery Compliance Officer (MSCO)
📧 Email: info@thenext.edu.np
📞 Phone: +977-01-4010523
🌐 Website: www.thenext.edu.np/modern-slavery-policy
