The UK Modern Slavery Act (2015) introduced restrictions and requirements for large organisations to publish a statement detailing their commitment to combating modern slavery from themselves and their supply chains.
What is modern slavery?
The term modern slavery covers the use of slavery, servitude, forced or compulsory labour and use of human trafficking. This also covers exploitation which includes:
- Sexual exploitation
- Removal of organs
- Securing services by force, threats or deception
- Securing services from children and vulnerable persons
You can find more information about the Modern Slavery Act on the National Archives website.
What actions are we taking?
We take the subject of modern slavery extremely seriously and have a zero-tolerance approach to slavery in all forms from both ourselves and our supply chain. We have committed to training relevant areas of the business, optimising our current procedures and policies and creating a supplier code of conduct.
Our statement describes all these areas and how we plan to contribute in the fight against modern slavery.
Modern Slavery and Human Trafficking Statement
Modern Slavery is a hidden crime and violation of fundamental human rights. It takes various forms, such as slavery, servitude, debt bondage, child labour, forced or compulsory labour and human trafficking, 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 and is extremely prevalent across the globe. The Walk Free Foundation estimates more than 40 million are victims of modern slavery, 71% female and 29% male. Of these, 15.4 million are in a forced marriage and 24.9 million in forced labour. Modern slavery impacts on all of us, from the food we consume to the goods we purchase. In the United Kingdom we spend circa £14billion on the top 5 at-risk imported products, garments, electronics (laptops, computers and mobile phones), fish, cocoa and rice. It is important that we do not deny or try to ignore the problem.
We are committed to improving our practices and policies, internally and throughout our supply chain, to combat modern slavery.
The University’s core business is teaching and research. We have a student population of approximately 26,000 based in the UK and Overseas. There are circa 2,600 staff employed across the University Group including its subsidiaries.
The University has its main campus in Derby with a large University presence right across the city of Derby. Both Higher and Further Education is provided in Buxton, Leek and Chesterfield.
There are ties to many major employers and public service providers in Derby, Derbyshire and Staffordshire. In addition, there are partnership arrangements in place with both UK and Overseas education institutions. In the financial year of 2018/19 we had an annual turnover of £192.4m.
Our supply chains
The University of Derby is committed to conducting its business in a socially responsible and sustainable way. Procurement manage the on-boarding of suppliers in which a due diligence exercise is undertaken for each supplier wishing to trade with the University.
We work with a diverse range of over 3,500 active suppliers all of whom have to agree and sign up to our Supplier Code of Conduct. For all tenders a declaration of compliance to Modern Slavery is confirmed by suppliers, this will be followed up regular audits but will be limiting for overseas suppliers.
Every competitive tender includes a requirement for the supplier to sign a Declaration of Modern Slavery Compliance and for risk or high value contracts, to respond to questions on the Ethical Trading Initiative (ETi) or have signed up to Net Positives where it is relevant and proportionate to the subject matter of the contract. Net Positives is a Supplier Engagement Sustainability tool for the Higher Education sector. It generates a sustainability action plan for businesses that is shared with the sector so suppliers do not have to repeat the same responses within different tenders. The suppliers are required to ensure their supply chain are ethical which includes aspects of Modern Slavery.
Our main supply chains fall under the following Categories:
Professional Services including agency staff, marketing, media and library
Estates and Facilities, construction, goods and services
ICT equipment and services
Corporate services and Technical
Our risk assessment
We have taken a risk based approach to identify commodities within the Categories that are a high risk for Modern Slavery and Human Trafficking, as a priority these are:
- Cleaning Services
- Capital building projects – construction workers
Suppliers within these areas that supply to the University will be monitored under the Supplier Code of Conduct and in the review meetings we have with our contracted suppliers on a regular basis we will ensure compliance to this Code. If any instance of Modern Slavery or Human Trafficking is suspected there is a National Modern Slavery Helpline to report these concerns. The University would direct anyone with concerns to the Helpline.
We are in the process of asking our preferred suppliers to undertake a supply chain mapping exercise to at least Tier 3 so that we can understand the ethical trading policies of downstream suppliers and/or manufacturers. This process will continue into this financial year.
It is our intention to identify these risks according to country (base location of supplier and any other connected countries relating to the supply chain) and sector and Tier 3 supply chain mapping will assist us in formulating a Modern Slavery Risk Mitigation Strategy. As new suppliers and commodity areas are identified a risk assessment will be undertaken and managed on a continuous basis.
Several of our policies refer to Sustainability, Environmental, Fairtrade and National Minimum Wage issues but none specifically on Modern Slavery therefore it is our aim this year to develop a stand-alone Modern Slavery Policy, outlining our statement of intent on how we manage suspected Modern Slavery and how we will work with our suppliers to ensure any risk is mitigated. This has not been developed this year so will be a priority in this financial year.
A review of our existing policies will be needed to incorporate our proposed actions.
Our due diligence
In order to prevent and embed Modern Slavery awareness within our University and in our supply chains, the following due diligence processes are undertaken:
- Any supplier refusing to agree to comply with the Supplier Code of Conduct will be removed from our supplier database;
- Contracts/Agreements will only be awarded if the supplier responds to the ETi questions, have an Action Plan in the Netpositives Supplier Engagement tool, or can demonstrate an understanding of Modern slavery and be able to identify risks within their supply chains;
- In our tenders we will encourage all suppliers to register on Netpositives where it is relevant and proportionate.
- We will register on Netpositives to access data from the suppliers.
- We will introduce Modern Slavery and Human Trafficking awareness as an Agenda item in our Procurement Team meetings and in our Fairtrade Steering Group with the possibility of having a separate Modern Slavery Working Group;
- We are encouraging more Fairtrade products within our Catering outlets including food, drink and clothing via the Fairtrade Steering Group;
- Category Management has been implemented and is moving forward to embed Modern Slavery awareness within all our activities;
- We will undertake due diligence when using external framework agreements even though the expectation is that they have already ensured their goods, materials and labour-related supply chains are fully compliant, transparent, accountable and auditable, and free from ethical ambiguities;
- We will include our staff, students, business partners and suppliers in the efforts to eradicate practices and issues arising from and affecting Environment, Sustainability, Ethical Business practices, Modern Slavery and Human Trafficking, the Modern Slavery Podcast will assist in this initiative;
- We will promote the Walk Free Foundation website which works towards ending modern slavery in all its forms by taking a strong, multifaceted and global approach
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, Procurement, along with the universities’ students, have written and filmed a video which highlights what Modern Slavery and Human Trafficking is, how to recognise Modern Slavery inside and outside the University and what steps we are taking to mitigate these risks. This video will be available for all staff and students, it will be embedded as part of our induction and training requirements and also advertised on our Intranet pages.
Procurement and Purchasing staff will complete the Chartered Institute of Purchasing and Supply’s ‘Ethical Procurement and Supply’ on-line training on an annual basis.
How we measure effectiveness
We will measure effectiveness by monitoring how many staff have registered and viewed the Modern Slavery video. We will work with the Student Union and Student Experience teams to agree a method of monitoring the effectiveness within our student community. We were unable to introduce a Modern Slavery Working Group but it is something we are still considering.
Members of the University’s Governing Council have reviewed this statement and gave its approval of the document in March 2020. It was then signed on behalf of Council by the University’s Vice-Chancellor and Chief Executive.
Professor Kathryn Mitchell BSc, PhD, CPsychol
Vice-Chancellor, the University of Derby