Peekaboo Nursery and Childcare Edinburgh


Modern Slavery and Human Trafficking Policy

Peek-a-boo Nursery School’s Modern Slavery and Human Trafficking Policy


This statement is made in accordance with section 54 of the Modern Slavery Act 2015 and sets out the steps that Peek-a-boo Nursery has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our setting or supply chain.

The business, Peek-a-boo Nursery is privately-owned nursery and was established in 1998 by Sally-Anne Peek.

Peek-a-boo Nursery School provides care for many children aged 0- 5 years across the Lothians and is committed to ensuring each child is given the best possible start.

We have elected to voluntarily adopt a statement to demonstrate our commitment to ensuring that modern slavery and human trafficking is not taking place within the business, with any partners or the supply chain that we work with.

Our modern slavery and human trafficking statement aims to show how we will act on the issue.

This statement will be reviewed and updated annually at the end of the financial year.

Policy Statement

Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.

Peek-a-boo Nursery has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

Peek-a-boo Nursery also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery and expects that its suppliers will in turn hold their own suppliers to the same standards.

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment.

In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, Peek-a-boo Nursery accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe, and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for Peek-a-boo Nursery in any capacity, including all colleagues, volunteers, agents, contractors, consultants, and any business partners.

Responsibility for the Policy

The Senior Management Team has overall responsibility for ensuring that this policy complies with Peek-a-boo Nursery’s legal and ethical obligations.

The Senior Management Team has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery.

They are also responsible for investigating allegations of modern slavery in Peek-a-boo Nursery.

Line Managers are responsible for ensuring that those reporting to them understand and comply with this policy.


The prevention, detection and reporting of modern slavery, is the responsibility of all those working for Peek-a-boo Nursery. You are required to avoid any activity that might lead to a breach of this policy. If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or report it in accordance with the Peek-a-boo Nursery whistleblowing policy. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of Peek-a-boo Nursery business as soon as possible.

If you are unsure about whether a particular act, the treatment of workers or their working conditions within the nursery constitutes any of the various forms of modern slavery, please raise it with your line manager.

You can also contact the government’s Modern Slavery Helpline on 0800 0121 700 for further information and guidance on modern slavery.

Peek-a-boo Nursery aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

Peek-a-boo Nursery is committed to ensuring no one suffers any detrimental treatment or victimisation because of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

Training and Communication

Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff on an ongoing basis as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases. Peek-a-boo Nursery zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering new or renewed contracts with them.

Breach of the Policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. Peek-a-boo Nursery may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

Associated Documents

The following internal policies procedures support Peek-a-boo Nursery to ensure that modern slavery and human trafficking is prevented and that human rights are maintained within the company and when working with the supply chain:

This policy works alongside these other specific policies:

  • Getting it Right For Every Child Policy and Procedures
  • Data Protection and Confidentiality Policy and Procedures
  • GDPR – Information about how we manage data Policy and Procedures
  • GDPR – Privacy Notice Policy and Procedures
  • Record Retention Policy and Procedures
  • Prevent Duty and Radicalisation Policy and Procedures
  • Domestic Violence, Honour Based Violence (HBV) and Forced Marriages Policy and Procedures
  • Child Protection Policy and Procedures


This policy works alongside specific National and local Guidance:

  • Health and Social Care Standards: My Support My Life
  • Getting it Right for Every Child
  • Inter-Agency Child Protection Procedures Edinburgh and Lothians


This policy works alongside specific National and Local Legislation and Guidance: 

  • The Equality Act 2010
  • General Data Protection Regulation (Regulation (EU) 2016/679 (GDPR)
  • Protection of Children (Scotland) Act 2003
  • Children and Young People (Scotland) Act 2014
  • United Nations Convention on the Rights of the Child
  • The Protection of Vulnerable Groups Act 2007
  • National Guidance for Child Protection in Scotland 2014
  • The Children’s Charter
  • Counter-Terrorism and Security Act 2015




This policy was adopted on Signed on behalf of the nursery Date for review
Feb 2021 Jennifer Gunn Feb 2022