Modern Slavery Statement 2022-23
1. Introduction
Incorporated by Royal Charter in 1905, the University of 91Ö±²¥ is a public research University and is an exempt charity under the terms of the Charities Act 2006. With a turnover in excess of £887m for the financial year ending July 2023, the University is defined as a commercial organisation by The Modern Slavery Act 2015 (Transparency in Supply Chains) which requires that any commercial organisation with a turnover of £36m or more to report each year on its efforts to identify, prevent and mitigate modern slavery in their supply chains,
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as human trafficking, forced labour, servitude and slavery, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
As part of the Higher Education sector, we recognise that we have a duty to take a robust approach in eradicating slavery and human trafficking throughout our supply chains. This annual statement sets out the steps the University of 91Ö±²¥ has taken in the last financial year and those we intend to take to address the issues of modern slavery, including human trafficking, forced and bonded labour and labour rights violations in our supply chains.
2. The University’s structure, business and supply chains
The University is one of the 24 universities that make up the . Members of this group are committed to maintaining the very best research, an outstanding teaching and learning experience, and unrivalled links with business and the public sector.
With over 30,000 students, 8,700 staff and strategic partnerships with many stakeholders, including local national and global organisations.
With over 30,307 students, 8,606 staff and strategic partnerships with many stakeholders, including local national and global organisations, we are dedicated to sector leading ethical and academic achievement across a broad range of disciplines. Our academic departments are grouped into the following five faculties:
- Faculty of Arts & Humanities
- Faculty of Engineering
- Faculty of Health
- Faculty of Science
- Faculty of Social Sciences
In addition to these Faculties, we have the Advanced Manufacturing Group (AMG), which is a network of world-leading research and innovation centres working with government agencies to support manufacturing companies of any size around the globe to be innovative and sustainable.
Faculties and the AMG are supported by Professional Services which is divided into the following structure:
- Chief Operating Officer Services
- Finance, Accommodation and Commercial Services
- Human Resources and Health & Safety
- Faculty Directors of Operation
The University is a member of the which is a member of . UKUPC is a partnership between eight UK purchasing consortia who created a formal entity to support collaborative procurement within Higher and Further Education. All eight consortia work together to share knowledge and best practice, to support each other and the wider procurement community.
We engage on modern slavery and sustainability issues with the wider university sector through our membership of the Higher Education Procurement Association (HEPA) and the national Responsible Procurement Group. Additionally, we are part of a Higher Education Sector focus group run by the Environmental Association for Universities and Colleges, working in a Social Value Task Force aimed at driving Social Value in our supply chains.
Spending money with a social and ethical conscience, supporting SMEs, focussing on renewable energy, and ensuring the goods and services we are procuring are free from modern slavery and human trafficking are just some of the aspects the university’s procurement team focuses on.
We have developed a methodology using the following assessment criteria on our 1st tier vendors (direct) The methodology is based on:
- Geographical Risk (based on vendor location)
- Higher Education (HE Procurement Category Risk –material codes)
- Level of skill within the category workforce
- Level of migrant/ seasonal workers within the category
- Level of third-party labour within the category
- Level of child labour within the category
Based on this criterion we have determined where the risk of Modern Slavery is deemed to be high, medium and low. Our assessment for the year ended 31st July 2022 is that no areas represent a high risk but that the following areas represent a medium risk:
- Estates and Buildings (construction)
- AV and IT equipment
- Laboratory supplies
We are assessing our risk for the year ending 31st July 2023 to ensure our position remains stable.
3. Our policies, due diligence, and procurement practices in relation to Modern Slavery and Human Trafficking
We continue to operate the following practices and due diligence in relation to mitigating and managing the risk of Modern Slavery in our supply chains.
- Vendors who bid for tendering opportunities are assessed against their compliance with International Labour Organisation standards and the Modern Slavery Act 2015.
- Staff whose primary job function is in a procurement role have received and continue to receive training from the Higher Education Procurement Association on Modern Slavery and Protecting Human Rights in the Supply Chain.
- Staff whose primary job function is in a procurement role are either qualified Members of the Chartered Institute of Procurement and Supply (MCIPS) or are actively working towards the qualification. A code of ethics is in place, which requires all MCIPs professionals to foster awareness of human rights, fraud and corruption issues in the supply chain.
- We engage with NetPositive Futures to address the requirements of the Modern Slavery Act in order to meet our disclosure responsibilities.
- We engage with our purchasing consortia (the NEUPC) and other HE procurement consortia on responsible procurement issues including (but not limited to) Modern Slavery and Human Trafficking.
- Using the HE Master Commodity Code Risk analysis tool we follow the National Procurement Policy Statement requirement to take measures in identifying and mitigating modern slavery risks during all stages of the procurement cycle.
- We have developed and are now in the process of implementing a procedure for vetting all new vendor setups, regardless of contract value on compliance with the Modern Slavery Act.
- We have adopted the HE Sector Code of Supplier Conduct and suppliers are required to understand and adhere to the principles contained within.
- We have affiliate membership of Electronics Watch via our purchasing consortia and obtain reports on identified issues they may affect our supply chains.
- We have re-undertaken the Governments Modern Slavery Risk assessment based on 2022/2023 performance. Our performance has increased from the 2021/2022 assessment.
4. Our future actions
During the financial year 2023/2024 we will:
Work with vendors who are deemed to be high to medium risk to assess their plans for mitigating the potential for Modern Slavery throughout their extended supply chains.
A dedicated Modern Slavery Policy will be developed that aligns with our Procurement Strategy, Procurement Policy and Vendor Management Policy.
Develop and roll out training to our vendors and the wider University on the indicators to Modern Slavery and what to do in the event it is suspected or identified.
Develop and introduce measurable Key Performance Indicators against the following elements:
- Training undertaken.
- Supply Chain verification
- Review of our existing supply chain
- Review our NetPositive Action plans.
- Undertake the Governments Modern Slavery Assessment against 2023/2024 performance to benchmark achievement of improvements.
Ensure Social Value questions including those relating to modern slavery are incorporated into every tender.
5. Training and measurement
We will continue to improve our training and awareness of the Act within the Procurement Team and the wider organisation.
We will work with our wider consortia on training suppliers on the issues around modern slavery.
Staff whose primary job function is in a procurement role will continually undertake professional development and training from the Higher Education Procurement Association on Modern Slavery and Protecting Human Rights in the Supply Chain. We will measure the number of people trained in both advanced and basic knowledge of the Act
6. Review and approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is reviewed annually. It was approved by the University Executive Board and signed by the President and Vice-Chancellor.
Professor Koen Lamberts
President and Vice-Chancellor
For and on behalf of the University of 91Ö±²¥
31 January 2024