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¶¹ÄÌÊÓƵ University Modern Slavery and Human Trafficking Statement 2016

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act) and constitutes ¶¹ÄÌÊÓƵ University’s (¶¹ÄÌÊÓƵ) modern slavery and human trafficking statement for the financial year ending 31st July 2016. This statement has been approved by the ¶¹ÄÌÊÓƵ Board who, together with the Audit, Risk and Governance (ARG) Committee, will review and update it as necessary on an annual basis.

¶¹ÄÌÊÓƵ takes a zero tolerance approach to slavery and human trafficking and has developed various policies and practices to achieve the highest levels of ethical and human rights principles in its business conduct. This statement highlights the extensive work undertaken across ¶¹ÄÌÊÓƵ to achieve this aim.  

¶¹ÄÌÊÓƵ’s structure

¶¹ÄÌÊÓƵ is a Higher Education Corporation created by statute and is an exempt charity. ¶¹ÄÌÊÓƵ is responsible to the Higher Education Funding Council for ¶¹ÄÌÊÓƵ (HEFCE) as principal regulator for Higher Education Institutions in ¶¹ÄÌÊÓƵ that are exempt charities. The ¶¹ÄÌÊÓƵ Board oversees the strategic development of ¶¹ÄÌÊÓƵ and ensures the effective use of resources and the general solvency of the institution. Its members are also ¶¹ÄÌÊÓƵ’s charitable trustees. Further details about ¶¹ÄÌÊÓƵ’s structure and governance can be found on the ¶¹ÄÌÊÓƵ website.

¶¹ÄÌÊÓƵ’s own business

¶¹ÄÌÊÓƵ’s business as a higher education provider is organised into several Faculties comprising; the Faculty of Health and Social Sciences, the ¶¹ÄÌÊÓƵ University Business School, Faculty of Media and Communication, Faculty of Science and Technology and also the ¶¹ÄÌÊÓƵ Graduate School. ¶¹ÄÌÊÓƵ also has several professional service departments which include, amongst others; Finance and Performance, Academic Services, Estates, Marketing and Communications, Human Resources and Organisational Development, Student Services and I.T Services. ¶¹ÄÌÊÓƵ has approximately 17,500 undergraduate and post graduate students who are attracted to ¶¹ÄÌÊÓƵ from all over the world.

¶¹ÄÌÊÓƵ is aware that its students may become aware of incidents of modern slavery or human trafficking as part of their daily lives or in very rare instances, may be entrapped into a life style of a modern slave. To address this, ¶¹ÄÌÊÓƵ has procedures in place whereby students can obtain support and advice on their wellbeing.

¶¹ÄÌÊÓƵ mitigates the risk of modern slavery and human trafficking within its own staff community by following fair HR recruitment and selection policies and procedures. Where recruitment agencies are used, ¶¹ÄÌÊÓƵ requires that such agencies comply with all UK legislation relating to the employment rights and welfare of candidates. ¶¹ÄÌÊÓƵ has an Anti-Slavery and Human Trafficking Policy and Procedures providing a reporting mechanism for all staff to raise concerns. In addition, ¶¹ÄÌÊÓƵ has a Whistleblowing (Disclosure in the Public Interest) Policy. 

¶¹ÄÌÊÓƵ supply chains

¶¹ÄÌÊÓƵ is one of the largest purchasers in the region and recognises that it has a responsibility to minimise the environmental and social impact of purchased goods and services. ¶¹ÄÌÊÓƵ has identified the following procurement areas as being at higher risk to modern slavery and human trafficking within the supply chain:

• Security Services
• Construction/ Estates Goods and Services
• Catering/Food Supply Chains
• Cleaning/ Domestic Services
• ICT Equipment/ General Electronics
• Clothing/Textiles

¶¹ÄÌÊÓƵ already has in place a number of frameworks which underpin its ethical standards across all of its business activities. ¶¹ÄÌÊÓƵ has a Sustainable Procurement Policy to ensure the purchasing of goods and services takes account of their environmental and social impact. ¶¹ÄÌÊÓƵ also has a Sustainable Food Policy, Fair Trade Policy and Procedures, Environmental Policy, an Ethical Investment Policy and Procedures and a Code of Ethical Fundraising and Donors’ Charter which ensures ethical standards of business conduct across the breadth of ¶¹ÄÌÊÓƵ’s activities.

¶¹ÄÌÊÓƵ purchases goods and services via the Crown Commercial Service (CCS). ¶¹ÄÌÊÓƵ is also a member of the Southern Universities Procurement Consortium (SUPC) which is a membership-based buying organisation for universities and further education colleges.  The SUPC is in turn a member of Procurement ¶¹ÄÌÊÓƵ Limited (PEL) which has published a shared Sustainability Policy to which all PEL member consortia are committed, and the SUPC has itself published its own Slavery and Human Trafficking Statement to demonstrate its work in relation to modern slavery and human trafficking.

¶¹ÄÌÊÓƵ policies and due diligence processes for slavery and human trafficking

¶¹ÄÌÊÓƵ’s Anti-Slavery and Human Trafficking Policy and Procedures reflects its commitment to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place in its supply chains.

As part of ¶¹ÄÌÊÓƵ’s initiative to identify risk it has in place systems to assess and mitigate potential risk areas in its supply chains, such as using the DEFRA Sustainable Procurement Prioritisation Tool. ¶¹ÄÌÊÓƵ also procures a lot of goods and services via consortium frameworks and has recently signed up to Electronics Watch (which assists public sector buyers to meet their responsibility to protect the labour rights of workers in their global electronics supply chains) and the Workers’ Rights Consortium (an independent labour rights monitoring organisation) to strengthen its due diligence processes. ¶¹ÄÌÊÓƵ also protects whistleblowers via its Whistleblowing (Disclosure in the Public Interest) Policy.  

¶¹ÄÌÊÓƵ has implemented a programme of contacting key suppliers in the higher risk areas to seek their assurances of compliance with the Modern Slavery Act 2015. During 2016/2017 ¶¹ÄÌÊÓƵ will continue to seek assurances from its major suppliers and will review its contracts with suppliers in light of the need to prevent modern slavery.

Supplier adherence to ¶¹ÄÌÊÓƵ’s values

¶¹ÄÌÊÓƵ takes a zero tolerance approach to slavery and human trafficking. To ensure ¶¹ÄÌÊÓƵ’s supply chain and contractors comply with its values, ¶¹ÄÌÊÓƵ has inserted Modern Slavery Act 2015 clauses into its standard terms of business for procurement. During 2016/2017, ¶¹ÄÌÊÓƵ will continue to review its contractual templates to address modern slavery where necessary.   

¶¹ÄÌÊÓƵ also has dedicated representatives who are aware of the requirements of the Modern Slavery Act from the following departments:

• Legal Services and Corporate Governance
• Human Resources
• Sustainability

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in ¶¹ÄÌÊÓƵ’s supply chains and its business, ¶¹ÄÌÊÓƵ will be providing training to relevant staff.

¶¹ÄÌÊÓƵ will also publicise the Anti-Slavery and Human Trafficking Policy and Procedures (the Policy) and the requirement to produce this statement on an annual basis to all staff.

¶¹ÄÌÊÓƵ’s effectiveness in combating slavery and human trafficking

¶¹ÄÌÊÓƵ will review the effectiveness of the Policy, training and other measures taken to combat slavery and human trafficking on a periodic basis.