Purpose

This Training Subcontracting Policy sets out INFRA Skills approach to subcontracting its Local Authority Adult Education Budget (AEB) provision. It outlines the framework that INFRA Skills uses in selecting and regulating subcontractors including the financial arrangements for subcontracted provision.

Introduction

1. For Infra Skills, the local authority funded courses continue to represent a natural extension of our work in supporting local residents to develop the skills to enable them to access employment within the rail and construction sector.

2. This policy applies to all subcontracted provision funded by the ESFA. The Subcontracting Policy is a mandatory requirement for subcontracting activity. The policy’s content has been developed to comply with the ESFA government funded provision.

Rationale for subcontracting

3. The main reason that Infra Skills subcontracts provision is to enhance the scope, reach and quality of our AEB offer. The specific reasons for choosing to subcontract would be one or more of the following:

• that a subcontractor would be able to provide access to specialist staff or other resources that would otherwise not be available
• that a subcontractor can widen access, participation and progression with groups that are hard to engage or geographically removed.
• that engaging with a particular subcontractor would bring benefits to the region in terms of business innovation and knowledge transfer.
• to satisfy particular needs (of employers/main provider) related to scope, reach or quality of AEB provision.
• to facilitate a seamless learning experience combining elements of provision delivered by INFRA Skills and its subcontractor.

Monitoring of subcontractors

4. INFRA Skills ensure all training sub-contractors are suitable and have up to date and adequate training facilities as well as suitably qualified staff, In addition:

1. the overall rationale for a proposed subcontract fits with INFRA Skills policies and strategy.
2. the subcontractor’s capacity and track record in providing high quality provision including that it is able to quality assure and improve relevant provision.
3. appropriate legal and financial due diligence checks are satisfied (including that the organisation is a legal person, it is not subject to legal proceedings to dissolve or wind up the company, it is up to date with submission of its statutory accounts and these have been subject to external audit by an independent and qualified auditor) and measures to identify any conflicts of interest
4. there are monitoring triggers and processes to intervene and terminate subcontracts as necessary, including continuity arrangements to transfer or support current Government Funded learners.

Compliance with ESFA rules and evidence requirements

5. Subcontractors are required to have robust internal policies to ensure compliance with legislative undertakings and general good practice and make certain that policies are regularly updated and effectively implemented, the requirements of which are identified in the contract. As a minimum any subcontractor will be expected to have a policy or policies covering the following topics approved at an appropriate level in the organisation:

• Employment law & appeals
• Data Protection (GDRP compliant)
• Health & Safety, Environmental and Quality
• Equal Opportunity/Equality & Diversity
• Safeguarding & Prevent
• Insurance: Employers (compulsory) Liability Insurance and Public Liability Insurance Cover
• British Values

6. INFRA Skills is responsible for ensuring that it satisfies the ESFA’s requirements for subcontracting. INFRA Skills General Training Manager will be the single, central point of contact with the ESFA.

7. In line with ESFA funding rules, INFRA Skills will submit a subcontractor use declaration of ESFA at least twice each year summarising the value of any subcontracted provision paid for in the previous period. INFRA Skills will also publish a summary of payments made to sub-contractors in the previous year on its website each year.

8. INFRA Skills should aim to improve the quality of training by contributing to the delivery and/ or assessment of the provision as appropriate to the particular apprenticeship programme.

Fees and charges

9. INFRA Skills and the subcontractor will agree training fees before any delivery takes place and the sub-contractors Terms and Conditions will be triggered at the point of booking and confirmation of training

10. In consideration of the fee, INFRA Skills will endeavour to provide the following support to the subcontractor

• initial needs assessment
• recruiting students, including the referral of delegates by INFRA Skills training co-ordinator staff, where appropriate to the needs of the student.

11. This Policy and an outline subcontract are available to current and potential subcontractors at the point that discussions are opened for new or reviewed subcontractor arrangements.

Richard Toy
Chief Executive Officer