Last updated: March 2023 // Approval: Approved by Board in Nov 2022
This policy is published on the Generation website and updated annually as the responsibility of the CEO. It concerns the use of subcontractors and supply chain members across our delivery.
This policy is a public version and summary of a more detailed internal procurement policy.
- Intent: From time to time Generation: You Employed, UK and Generation: You Employed, Ireland (both referred to “Generation” hereafter with both organisations following this policy) will subcontract delivery of services to third parties or “supply chain members”. This could include, not exhaustively, instruction and mentorship delivery for example. We will do so where subcontracting allows Generation to more effectively, efficiently or impactfully deliver its charitable mission, strategic and operational aims. We will only do so where permitted by and in line with the terms of our funding arrangements and agreements.
- Quality: When working with supply chain members to deliver learner or beneficiary facing services Generation commits to work together with supply chain members to improve the quality and effectiveness of that delivery as if it were delivered by our colleagues. Supply chain member delivery will be regularly observed by Generation team members and regular review meetings conducted with action plans and recommendations for improvements made on the basis of observation and collected data — including learner feedback and learner outcome data. Each supply chain member will have a designated Generation colleague responsible for review and improvement of their quality. A precise plan of performance review will be agreed with each supply chain member before the start of delivery. Where supply chain members are found to be under-performing a performance improvement plan will be documented and agreed. If further improvements are not made Generation may seek to terminate work with the supply chain member.
- Costs and fees: Generation will agree delivery costs with supply chain members in advance of beginning any delivery. Costs will only be agreed to where they are reasonable and proportionate.
When subcontracting to a supply chain member, Generation will take seriously the management and oversight required and is aware it will incur cost in so doing. This cost in most cases will be equivalent to a small proportion of the time of members of colleagues involved in overseeing delivery. In most cases, this is estimated, reasonably and proportionately for the delivery of high quality work, to account for less than a >£1k per supply chain member per bootcamp as there is little marginal increase in cost to Generation from managing partners as part of its cohort delivery as compared to full time staff. Where the cost incurred is expected to be significantly different, Generation will inform the supply chain member.
- Management: Generation will enter into a contract with all subcontractors and supply chain members. This contract will explain the purpose of the work together and clear deliverables expected of the supply chain member. As well as this the contract will include payment terms as well as Generation’s commitment to the supply chain member and lay out the monitoring and review process (including Generation’s estimate of the costs incurred in managing the partner). Where subcontractors are working with learners, subcontractors will sign and follow Generation’s safeguarding policies and processes. DBS checks will be conducted for subcontractors working with young people and vulnerable adults, in line with our safeguarding policy Generation will document a contract lead and a team member responsible for ensuring the subcontractor is delivering high quality work.
- Due Diligence: When appointing new supply chain members to contract, Generation will conduct a due diligence check on the organisation or individual. Specifically Generation will check and confirm the following (where relevant and for all contracts over £10,000 — noting some of these steps may not be possible for individual freelancers, or appropriate for smaller contracts):
- The organisation or individual does not appear on a specific watchlist (using LexisNexis risk solution and/or Bridger Insight XG). Specifically checking against the provisions or areas highlighted in the Anti-Terrorism policy.
- The organisation’s existence and financial standing (e.g. an “active” status on Companies House), via a register search, and that financial accounts are not overdue
- There is not above average risk via a financial credit check (where relevant) and that the organisation has not passed a resolution (or the court has made an order) to wind up or liquidate the company or has appointed administrators
- There is not adverse news/media or evidence of any other evidence activity that may be either criminal, have a negative reputational effect on Generation, be mission misaligned, or linked to terrorism. If notable or significant risks present a detailed review process will be conducted with final sign-off provided by the board.
- Any potential conflicts of interest are documented and a plan for their management exists
- (where relevant) The latest Ofsted reports do not conclude as “insufficient process made” or “inadequate”
- The organisation has clear practices and or a policy for preventing slavery and human trafficking and (where relevant) is compliant with annual reporting requirements as in section 54 of the Modern Slavery Act
- If appointment of subcontractors is made in part due to the qualifications/certifications that they have, that these are valid.
- Procurement: Where Generation requires delivery of a new service for a contract of more than £10,000 (and/or predicts future or repeat engagement (in the next year from the intended procurement date) with total more than this value), Generation will advertise the opportunity on its website for >10 days (including requirements, how to apply, and how the successful candidates will be chosen), proactively engage organisations already engaged with Generation and known to deliver similar services and target receipt of at least three** written quotes and assess bids against a scorecard of set of criteria (including value for money, track record, and suitability). For contracts >£150,000 a more detailed plan will be made outside of the scope of this document. Generation will as standard only procure services to one level — i.e. Generation will not procure contracts or enter into agreement with supply chain members where to deliver the work required supply chain members need to subcontract again to another party unless explicit approval is provided by Generation.***
**Exclusions/exceptions to the need for three quotes may apply in a situation where:
- we do not receive sufficient interest despite a publicly available advert and promotion on Generation channels
- services are very specialist and only one source can provide sought items and services to a sought standard
- a specific partnership has been formed in order to tender for a specific piece of work in advance
- a non-competitive appointment has been approved by relevant funding authorities, (v) delay would lead to potential harm to individuals (specifically our beneficiaries), and/or
- work is part of a broader partnership agreement between two organisations with Generation providing services/support in return.
In these circumstances the rationale must be documented and approved by a senior Generation staff member.
*** Exceptions may occur for example where another third party is a standard part of the service being procured/offered and/or where Generation works with ‘agencies’ that contract to individual instructors or individuals. In this case Generation will enter into a contract with the agency and ensure the individual to whom the agency subcontractors is brought through the same onboarding and management processes as if they were an individual or direct subcontractor.
- Onboarding: subcontractors must agree to the policies and procedures outlined in our contractor handbook including (but not limited to) safeguarding policy, ED&I policy, health and safety, anti-bribery and money laundering