Code of Business Conduct
Modern Slavery Transparency Statement 2024
Customer Care Policy
Strategic Aims
Governance for Subcontracting
Learner Welfare and Safeguarding Policy
Environment and Sustainability Policy
Health and Safety Policy
Learner Equality, Diversity and Inclusion Policy

code of business conduct

our policy: inspiro will conduct its business to the highest standards of honesty and integrity.


Simply, it is the right and proper thing to do and it is in Inspiro’s and our employees’ best interests:
Our reputation and good name are our greatest assets; they are easily lost by actual or suspected corrupt or unethical behaviour. Without them we will lose business and jobs.

Corrupt behaviour can be criminal behaviour: the company and employees can be prosecuted, fined or imprisoned. Conviction can ruin individual careers, lead to existing contracts being terminated and disqualification from bidding for others, with a consequent loss of jobs.

what our code of business conduct means


  • WILL respect the dignity and rights of its employees and place the highest priority on ensuring the safety of each other at work and the safety of others who might be affected by our activities;
  • WILL seek to minimise so far as we reasonably can the impact of our activities on the environment;
  • WILL comply with the law in the conduct of our business;
  • WILL be honest in our dealings with those with whom we do or seek to do business;
  • WILL strive to avoid even the appearance of wrongdoing or impropriety in the way we go about our business;
  • WILL NOT bribe or attempt to bribe anyone;
  • WILL NOT take bribes from anyone;
  • WILL be diligent in selecting our business advisers and partners so that we minimise the risk of our reputation being damaged by others;
  • WILL implement and observe appropriate training and procedures designed to ensure that we and others working for us understand what our Code of Business Conduct means for them in practice; and
  • WlLL treat seriously breaches of our Code or its associated Guidance.

And our employees:

  • WILL avoid (or properly disclose and obtain clearance for) potential conflicts between their interests (or those of their friends and families) and their responsibilities to Inspiro or our customers;
  • WILL NOT take bribes and will report to appropriate management any attempt made to bribe or improperly influence them or another employee in the carrying out of their duties for Inspiro;
  • WILL NOT bribe or attempt to bribe anyone (including by making “facilitation payments” and will report to appropriate management any request or suggestion that Inspiro, or anybody working for or with Inspiro, should bribe or attempt to improperly influence someone;
  • WILL seek advice on how to proceed if they are at all unsure whether something complies with our Code of Business Conduct or how to apply its associated Guidance;
  • WILL be able to raise (confidentially if they wish), without fear of unfavourable consequences for themselves, any genuine concerns they have that our Code or its associated Guidance is not being followed.

And our Business Advisers

  • MUST agree to comply, and actually comply, with our Code and this Guidance, so far as relevant to them, as if they were our employees.

And our Business Parnters

  • SHOULD either be willing to subscribe to our Code and its associated Guidance or have equivalent standards and procedures in their own businesses.

modern slavery

We are committed to the protection of human rights and we respect all international treaties including the United Nations Declaration on Human Rights and the UK Modern Slavery Act 2015. Modern Slavery considerations are included as part of our risk management and supplier selection processes and we will continue to review our approach to training our employees and ascertaining risks in regard to the prevention of modern slavery.
We expect our suppliers and extended supply base to comply with this legislation.
Where it is discovered that there has been a breach of the above, or any other relevant declarations and legislation, we will take all necessary steps to mitigate any impact.

modern slavery transparency statement 2024


This statement relates to Inspiro Learning Limited, covering all business regions within the
United Kingdom of Great Britain and Northern Ireland. The statement relates to the financial
year ending 31 March 2025.

organisational structure

Inspiro is a UK based business delivering skills training, technical training, and apprenticeships
nationally across a diverse range of sectors underpinned by supportive account management
practices. We support our clients by designing and delivering employer-led programmes that
provide life changing, career shaping skills and experiences for their employees.
We deliver both on site and remotely for our clients across the UK inclusive of Scotland, Wales
and Northern Ireland; and for our Automotive and Rail clients we have an Academy based
training and apprenticeship delivery. Inspiro also provides a fully Managed Learning Service
to the Automotive and Nuclear sectors.

In order to fulfil its activities, the main supply chains of Inspiro include those related to the
supply of goods and services from various suppliers in the United Kingdom
Inspiro operates as a single standalone business and is owned by London-based investment
firm Inspirit Capital, having previously formed part of the Babcock International Group’s civil
training business.


Inspiro considers that modern slavery encompasses:

  • human trafficking
  • forced work, through mental or physical threat
  • being owned or controlled by an employer through mental or physical abuse of the threat of abuse
  • being dehumanised, treated as a commodity or being bought or sold as property
  • being physically constrained or to have restriction placed on freedom of movement


Inspiro acknowledges its responsibilities in relation to tackling modern slavery and commits to
complying with the provisions in the Modern Slavery Act 2015. We understand that this
requires an ongoing review of both our internal practices in relation to our labour force and,
additionally, our supply chains.

Inspiro does not enter into business with any other organisation, in the United Kingdom or
abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced
or compulsory labour.

No labour provided to Inspiro in the pursuance of the provision of its own services is obtained
by means of slavery or human trafficking. Inspiro strictly adheres to the minimum standards
required in relation to its responsibilities under relevant employment legislation in the UK and
in many cases exceeds those minimums in relation to its employees.

customer care policy

Please click here to view our Customer Care Policy (PDF).

strategic aims

Our programmes are built to respond to the complex requirements nationally across a diverse range of sectors, the employers we work with and delivery models consider the current and emerging needs of learners, their working environments and wider skills development.

Curriculums which include delivery from partner providers are key to our response to national and local needs.

We recognise the requirement to reduce the volume of subcontracted ESFA post-16 income and have such, developed a clear strategic framework for the use of sub-contractors in ESFA procured and non-procured activity.

In line with the requirement, we will only consider sub-contracting elements of our ESFA funded provision in the following circumstances:

  • To utilise subject matter expertise where it doesn’t exist within Inspiro
  • To support better geographical access for learners and the requirements of employers
  • To provide experiential learning opportunities which add value to the learners experience

governance for subcontracting

Any curriculum which is enhanced by the use of sub-contractors for specific elements will have an educational rational for the subcontracted provision in place. These will be agreed before delivery with the CEO and Senior Management Team.


The Procurement & Supply Chain (P&SC) strategy is adopted across the business. We recognise suppliers as a vital extension to our business and a fundamental component in achieving businesses objectives.

Any aspect of ESFA funded delivery that is subcontracted to a third party is managed by P&SC with a robust key supply management activity. This activity is supported by subject matter experts (SMEs) from the operational contract and quality assurance activity from the quality teams.

due diligence

All potential partner providers undergo through due diligence which includes:

  • Financial stability – a fit-for-business assessment
  • Suitability against requirement – a fit-for-purpose assessment
  • Organisational overview – management structure, directly employed staff, any outsourced activity
  • Evidence of appropriate capacity and expertise of staff
  • Evidence of previous delivery and results
  • Consideration of added value
  • Robust quality assurance systems
  • Current status with ESFA / other funding bodies and totality of provision with other providers
  • Evidence of required registers and accreditations such as the RoATP

contract management

Once a contract is in place, regular meetings between P&SC and the supplier will be scheduled to check operational performance against the SLA and KPIs.

Stakeholders, including a nominated quality lead and an operational lead, will contribute at such reviews. The reviews provide a forum where all issues (positive and negative) are addressed and where required remedial actions agreed and monitored. Progression monitoring, safeguarding / welfare concerns and learner / employer complaints are mandatory returns from all sub-contractors.

Continued underperformance will be managed accordingly and could include suspension of the subcontractor from the contract and starting a process to identify a suitable replacement. where this action is taken, it shall be done in a timely manner and will focus on minimising the impact to learners. If a new subcontractor is proposed, or changes to current contracts agreed, P&SC will lead the activity in conjunction with the contract and quality lead. This process includes a review of the educational rationale for sub-contracting for the curriculum which requires re-approval from the Director of Inspiro.

management fee policy

Inspiro do not subcontract whole programmes. Provision that is subcontracted relate to specific elements of Apprenticeship Programmes and costs for delivery are agreed with each subcontractor, Inspiro does not charge a management fee for this element of subcontracting.

The following support and facilities will be made available to subcontracting organisations at no additional charge to them

  • Allocated contract manager to provide support on the management and administration of the subcontracted provision and answer any enquiries
  • Updates on key sector information including funding and eligibility changes
  • Learner data audits to ensure compliance against ESFA guidelines
  • Quality assurance audits detailing all feedback and recommendations
  • Teaching and learning observations and learner feedback to provide feedback and support to improve the quality of provision

When there is a clear educational rational for the use of sub-contractor, a dedicated procurement process is undertaken and partner providers are invited to quote for and receive 100% payment for the work they do.

payment terms

We want to spend time talking to our suppliers about new ideas, operational performance and total cost opportunities – not about payment. We understand the importance of predictable customer payments when running a business. Inspiro is a signatory in the UK to the Prompt Payment Code and we would encourage others to do so.

Our suppliers have a critical responsibility for getting paid on time – by delivering on time and in full, following the required billing processes, and adhering to our standards for invoicing.

subcontractors in active partnerships with inspiro learning

learner welfare and safeguarding policy

Please click here to view our Learner Welfare and Safeguarding Policy (PDF).  

environment and sustainability policy

Please click here to view our Environment and Sustainability Policy (PDF).

health and safety policy

Please click here to view our Health and Safety Policy (PDF).

learner equality, diversity and inclusion policy

Please click here to view our Learner Equality, Diversity and Inclusion Policy (PDF).

We're now Inspiro, imagine more