POLICIES & PROCEDURES

Here are the details of all our policies relating to safeguarding of LCBT students, equality, behaviour, diversity and inclusion, and our commitment to students with special educational needs and disabilities.

Here you can read our Special Educational Needs and Disability (SEND) Policy.

SEND Policy

Here you can find our policies relating to staff conduct and managing allegations, as well as details of how we receive and process feedback. Whether we have done something amazing or could improve on something in future, you contact us at talkback@lcbt.co.uk

Here at LCBT, we expect all staff and learners to be treated and to treat others with respect. Our aim is to provide a working and learning environment free from harassment, intimidation or discrimination in any form that may affect the dignity of the individual.

If any learner or staff member feels that they have been unfairly discriminated against due to race, religion, belief, nationality, ethnic origin, sex, sexual orientation, marital status, age, disability or domestic circumstances please contact talkback@lcbt.co.uk for advice, support and guidance.

If you have any ideas for us to consider in this regard, please email the same email address with your suggestions.

The College vision, mission and values are important because they provide the College with the means to work together in a learning community, despite our many individual differences. We expect all staff and learners to subscribe to these values, regardless of their faith or beliefs.

LCBT believes that every individual should be treated with courtesy, fairness and we respect the rights and beliefs of each other, regardless of gender, marital status, age, disability, race, religion, sexual ordination or position within the organisation. Any individual, who opposes these values due to personal, religious or cultural beliefs, must expect their viewpoint to be challenged by the College community.

For full details of LCBT’s Vision, Mission and Values, click here

Course related fees and booking deposits can only be refunded in full if a course is cancelled by the college. Deposits for tuition fees, kits or examinations cannot be refunded in the case of illness, personal problems, relocation, change of work, lack of visa or any other reason that may mean you have to cancel or leave your course.

THAT NAIL PLACE LIMITED – TRADING AS TNB SKILLS TRAINING

POLICY STATEMENT

The London College of Beauty Therapy Ltd (LCBT) is committed to enhancing and diversifying the range of curriculum programmes that complement and widen our own curriculum offer and diversify the range of opportunities to re-engage young people and adults in learning and training. Working with high quality organisations and nurturing quality with smaller training providers allows the College to achieve this goal and ensures that quality provision can be delivered to a wider geographical area, especially reaching learners where access to the curriculum is limited.

REVIEW & POLICY RATIONALE

LCBT is pleased to continue with the existing subcontracting arrangements with TNB Skills Training in relation to 16-18 Traineeship and to complete the remain few 19-23 traineeships from the 2022/23 academic year that have rollover over in to the 2023/24 academic year in order to complete their traineeships and record their progression. LCBT has been a subcontracting partner with TNB Skills Training for over 9 years, supporting, developing and nurturing their development and provision in order to provide high quality learning provision to learners in particularly disadvantaged areas of the South-East where the learners engaged may not have had the access to such opportunities otherwise to the type of learning provision, providing an entry point for the most disadvantage learners in the area. TNB Skills Training provides better access to training for learners in residing in areas of high deprivation within the geographical areas of Sittingbourne and Folkestone. Specialising in referrals from local schools, Job Centre Plus (JCP), Community Youth Projects, Connexions and the Local Authority, learners are generally in the high priority Not in Education, Employment or Training (NEET) category as well as those who are unemployed and low income seeking pathways to employment. LCBT are pleased with TNB Skills Training’s past performance and are happy to continue to support the learners they are engaging in the supported areas as well as to continue to support the development of their training provision which in turn supports the learning provision in the area where it is not readily available by other training providers. These reasons align with both the ESFA guidance for subcontract rationale and LCBT’s own strategic aims and enhances the quality of learning for learners in the disadvantaged areas of the South-East of England.

This means that the education rationale meets the following aims:

Enhances the opportunities available for learners
Fills gaps in niche or expert provision and provides better access to training facilities.
Supports better geographical access for learners
Offers an entry point for disadvantaged groups.

CONFIRMATION OF FUNDING

In the allocation of learning provision funding percentages to TNB Skill Training, LCBT has taken in consideration the effects that would be applied to possible future funding allocations to LCBT based on the lower area uplift for provision and some lower programme uplifts for TNB Skills Training’s proposed provision as well as any withdrawal funding reductions in to account.

80% Learning Provision Funding from ESFA Funding all 16-18 Traineeships
80% Learning Provision Funding from ESFA Funding rollover from 22/23 academic year completions and progressions ONLY for 19-24 Traineeships into the 23/24 academic year.

SPECIFIC COSTS OF SUBCONTRACTING MANAGEMENT

SUBCONTRACTING RATIONALE POLICY REVIEW

The subcontract will meet the agreed educational needs in relation to the delivery of Traineeship provision and it is deemed affordable and achievable upon review. Possible alternatives have been considered but not suitable and if the continuation of the Traineeship provision with TNB Skills Training was not able to take place, subcontracted provision would immediately cease at LCBT and formally reviewed for subsequent academic years. Contingency plans for subcontracts can be found within LCBT’s Business Continuity Plan/Policy and LCBT’s Subcontracting Policy.

No additional subcontracting services will be required in addition to those specified and contained within the Subcontracting Rationale for the 2023/24 academic year.

The Subcontracting Rationale is reviewed annually in the month of July. Next scheduled review is for 2024.

To view the full approved and signed copy of LCBT’s Subcontracting Rationale for the 2023/24 academic year, please click HERE.

SUPPLY CHAIN FEES AND CHARGES

Please in below LCBT’s published supply chain fees and charges for the academic year 2016/17.

For the academic year 2013/14 please click here to download the financial information in relation the college’s SFA subcontracted delivery.

For the academic year 2014/15 please click here to download the financial information in relation the college’s SFA subcontracted delivery.

For the academic year 2015/16 please click here to download the financial information in relation the college’s SFA subcontracted delivery.

For the academic year 2016/17 please click here to download the financial information in relation the college’s SFA subcontracted delivery.

Subsequent academic years post 2016/17 subcontracting information are submitted directly to the ESFA (Education & Skills Funding Agency) and publicly published by the ESFA here: https://www.gov.uk/government/publications/sfa-subcontractors-list

SUBCONTRACTING

Requests for subcontracting opportunities is now closed for 2023/24.

LCBT’s SUBCONTRACTING / SUPPLY CHAIN FEES AND CHARGES POLICY

POLICY STATEMENT

The London College of Beauty Therapy Ltd (LCBT) is committed to expanding and diversifying the range of curriculum programmes that complement and widen our own curriculum offer and diversify the range of opportunities to re-engage young people and adults in learning and training. Working with high quality partner organisations and nurturing quality smaller training providers allows the College to achieve this goal and ensures that quality provision can be delivered to a wider geographical area, increasing, enhancing participation and the employability of learners. To ensure and provide some initial assurance, LCBT expects all potential subcontractors to be included on the Education Skills Funding Agency’s Register of Training Organisations and successfully pass an initial prequalifying questionnaire and subsequent due diligence process including having their capability to deliver programmes assessed before applying for a subcontractor through LCBT. LCBT only subcontracts the provision of full programmes which are classified as ‘Provision Subcontracting’.

SCOPE

The policy applies to all subcontracted partner organisations and training providers.

IMPROVING THE QUALITY OF TEACHING AND LEARNING

LCBT will support the quality of teaching and learning of partner organisations and training providers through the development and sharing of good practice; curriculum and quality reviews; observations of teaching, learning and assessment, together with analysis of learner and employer feedback.

PUBLICATION OF INFORMATION RELATING TO SUB-CONTRACTING.

In compliance with the Education and Skills Funding Agency (ESFA) and other agency funding rules that apply, the College will publish its subcontracting fees and charges policy on its website before the start of each academic year (and in the case of actual end of year data, as required by ESFA). LCBT will only provide ‘provision subcontracting’ and therefore the policy will only relate to ‘provision subcontracting’ i.e. subcontracted delivery of full programmes or frameworks. The policy will not include the delivery of a service as part of the delivery of a programme (for example, buying the delivery of part of an Apprenticeship framework or outreach support). The College will ensure all actual and potential subcontractors have sight of this policy and any other relevant documents.

Our overall rates of subcontracting for the academic year 23/24 will normally be 20% of the funding received which would be provided to the subcontractor for the delivery of the subcontract. Variations can apply, this will depend on the level of support required for each subcontract and the potential risk. Some subcontracts may contain performance related criteria, where if not met, may decrease the amount of funding the subcontractor may receive. This is both to promote quality provision and to compensate for possible negative consequences to future funding for LCBT. All subcontractors are made fully aware of this before agreeing and commencing subcontracted provision.

Below is an example of a typical breakdown of the specific costs in relation to a 20% subcontractor management cost to support and manage the subcontracted provision.

THE SUPPORT SUBCONTRACTORS WILL RECEIVE IN RETURN FOR THE FEE YOU CHARGE

This figure represents the cost that the London College of Beauty Therapy (LCBT) incurs in effectively identifying, selecting and managing each specific sub-contracted provision. The cost covers the additional support LCBT deems necessary to ensure the quality of education and training, including the administration, processing, auditing and support provided in relation to the information provided, as well as periodic reviews/meetings. It also takes in to account any negative effects in relation to funding to LCBT that supporting a quality subcontract may occur.

PAYMENT TERMS BETWEEN YOU AND YOUR SUBCONTRACTORS – TIMING OF PAYMENTS IN RELATION TO DELIVERING PROVISION AND TIMESCALE FOR PAYING INVOICES AND CLAIMS FOR FUNDING RECEIVED

We pay our subcontractors within 30 days of invoice issued, normally by the 28th of each month. Certain delivery programmes as part of a subcontract may have different payment criteria based on the agreed contract which may include payment upon achievement of objectives/goals or payment made at end of programme upon receipt of all required information and evidence.

CONTINGENCY PLAN FOR WITHDRAWAL OF DELIVERY FROM SUBCONTRACT ARRANGEMENT

In the event of a subcontractor withdrawing from the arrangement under any circumstance, or if a subcontractor goes in to liquidation or administration, in compliance with the ESFA funding rules that apply, LCBT will undertake direct management and delivery of the remainder of the agreed provision already being delivered. The delivery will continue through one of two methods:

Directly delivered by LCBT’s own existing staff, resources and expertise.
LCBT retaining the existing structure of the subcontractor’s delivery, and in the case of liquidation or administration retaining any tutor expertise, specialist equipment, resource needed to aid the completion of the existing learners on programme.

The decision will be based on a review of viability, maximum opportunity for the existing learners to complete their programmes and cost-effectiveness. Any provision that has been planned but started will be cancelled and on the completion of the existing learners, the learning programme closed.

If in the event that LCBT need to withdraw itself from a subcontracting arrangement, sufficient notice will be provided to allow the subcontractors to complete the delivery of the current existing provision. In this event LCBT will provide:

support to enable effected subcontractors to identify other sources of funding if possible.
where possible, take appropriate action to complete the existing learning programme.
close the learning programme where possible at its earliest opportunity.

All actions would be undertaken with our any prejudice to the existing enrolled learners and/or staff.

Contracts clearly state the conditions of termination and recovery of ESFA funding in the case of any parties withdrawing from delivery/subcontract arrangement.

CONTINGENCY PLAN FOR MANAGEMENT OF THE SUBCONTRACT

In the event of the current Contract Manager not being able to continue their duties as the Contract Manager, the remaining members of the Executive Team, the CEO/Principal, COO and the Financial Director both have the experience, knowledge and capacity to undertake the responsibility of the Contract Manager until which point it is deemed necessary to delegate another suitable member of staff or recruit into the role.

All other contract operational functions such as MIS/Audit, Curriculum and Quality and Safeguarding all have additional members of staff who are experienced in those areas and would be able to take up those functions in relation to the management of the subcontracts should any of the current members of staff are unable to continue their duties.

PERFORMANCE AND TRACKING

The management of subcontractor performance is to monitor, review and evaluate in order to inform corrective, preventative and improvement actions and manage risk through contingency planning.

LCBT will manage subcontractor performance on the basis of:

Monitoring performance on a risk assessed basis;
Assessing and reviewing outcomes with the subcontractor;
Determining proportionate action to address any areas of concern or requiring development.

Monitoring of performance will include the following activities and timescales. Where risk is considered to be high then the frequency of monitoring activities will be increased and the subcontractor.

The timeliness, error rate and frequency of errors on monthly data returns
Performance against profiled starts, on programme payments, retention and achievement rates will be assessed every month.
Provision of awarding body reports, particularly External Quality Assurer (EQA) reports within 1 week of their receipt by the subcontractor

File audits will be conducted every 3 months to check that they are accurate and up to date including that learners existence, are eligible, enrolled on the appropriate programme, that training is taking place and that the require planned learning hours are recorded.

The quality of teaching and learning will be assessed every 3 months through:

Examination of learner portfolios
Awarding body reports including IQA
Minutes of standardisation meetings
Observation of teaching, learning and assessment including paired observations which will include initial and diagnostic assessment, induction, planning training, on and off the job training and assessment involving 121 and group sessions and coherence across the on the job and off the job elements, provision of Information Advice and Guidance and reviews
Discussions with staff, learners and employers to ensure that all parties are aware of the role and responsibilities of LCBT and the subcontractor
Ad-hoc short notice visits that may focus on any particular aspect(s) of the subcontracted provision, e.g. the Learner Journey, Safeguarding, Prevent, etc.
Annual employer and learner surveys conducted by the prime on behalf of the subcontractor.

All subcontractor monitoring and tracking actions are recorded with the subcontractor’s performance tracker. Where performance of the contract does not meet the standards set out within the contract, LCBT have the options to restrict or suspend delivery, vary or terminate the contract dependant to performance severity.

HOW AND WHEN THE POLICY IS COMMUNICATED TO AND DISCUSSED WITH CURRENT AND POTENTIAL SUBCONTRACTORS

During the subcontractor qualification and engagement stage, LCBT’s approach and procedures in relation to subcontracting are discussed and reviewed with potential subcontractors. This is further reinforced during the contract negotiation stage and reinforced on a regular basis during subcontracting period.

TIMING FOR POLICY REVIEW

LCBTs subcontracting policy is reviewed on an annual basis at a senior management level. Last review of the policy was conducted on the 17th July 2023. The next review will be scheduled for July 2024.

WHERE IS THE POLICY PUBLISHED

This is LCBT’s Subcontracting Policy / Supply Chain Fees and Charges Policy which is on the LCBT website.