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
This statement for the University of Derby Group of Companies covers the period from 1 August 2020 to 31 July 2021.
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 who collates The Global Slavery Index, estimates that in 2018, 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.
The majority of children reported as victims of Modern Slavery are in the 16-17-year-old age category, yet they can be of any age, including the very young. Section 11 of the Children Act 2004 places duties on a range of organisations and individuals to ensure their functions and any services that they contract out to others are discharged having regard to the need to safeguard and promote the welfare of children.
Modern slavery impacts on all of us, from the food we consume to the goods we purchase. In the United Kingdom, we spend circa £18billion on 3 of the top 5 at-risk imported products, garments, electronics (laptops, computers, and mobile phones) and fish. It is important that we do not deny or try to ignore the problem.
We are committed to safeguarding our students and vulnerable adults, improving our practices and policies, both internally and throughout our supply chain, to combat modern slavery.
The University’s core business is teaching, learning 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 2020/2021, Group turnover was £201m.
Our supply chains
The University of Derby is committed to conducting its business in a socially responsible and sustainable way. The Procurement team manage the on-boarding of suppliers in which a due diligence exercise is undertaken for each supplier wishing to trade with the University Group.
The Group works with a diverse range of 2,412 active suppliers, all of whom have to agree and sign up to our Supplier Code of Conduct.
Every competitive tender includes a requirement for the supplier to sign a Declaration of Modern Slavery Compliance and from Financial Year 2021/2022 the Sustain Supply Chain Code of Conduct, developed by HE consortia will also be included as part of the tender process. For medium/high risk or high value contracts, to also respond to questions on the Ethical Trading Initiative (ETi) or have signed up to NETpositives, where it is relevant and proportionate to the subject matter of the contract. NETpositives 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. It helps suppliers to understand the positive contribution their business makes to the environment, society, and the economy. This can be used to track the actions being taken and progress being made by the University’s supply chain in addressing aspects of Modern Slavery.
- 902 suppliers have registered
- This represents 37% of active suppliers
- 83% of these are SMEs (small and medium-sized enterprises)
- 3% are local SMEs
- 97% are aware of Modern Slavery
- 69% have made a public commitment to taking action against Modern Slavery
- 502 Modern Slavery actions have been committed to
- 146 have been completed or are in progress
- 146 pieces of evidence have been provided
Evidence of impact from suppliers
“ …eliminate and prevent modern day slavery from occurring in our supply chains. As we recognise the importance of this, we have a number of codes of conduct and policies in place to support our approach to eliminate modern day slavery.”
“Improvements to supplier on boarding and supplier management processes to take into account at risk human rights issues in supply chain - inviting suppliers to sign up to company supply ethics policy.”
“We ask our suppliers to provide details of their policy and the procedures used to check their own supply chain.”
“Any non-compliance with our policy on Modern Slavery will result in a Corrective and Preventative Action Plan being created, this will be subject to Management Review and internal and external Audit.”
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 STEM
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 that are held with contracted suppliers on a regular basis compliance to this Code is ensured. 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.
The University has commenced supply chain mapping of specific products within high-risk category areas identified above.
For example, our desk top wood is sourced from Switzerland, with PB/superpan sourced from Portugal and particle board from Spain.
Both Portugal and Spain are not in the top ten high risk countries as identified in the Global Slavery Index 2018 and the International Labour Office.
This will be an ongoing, detailed process to investigate even more of the supply chain.
Several of the University’s policies refer to Sustainability, Environmental, Fairtrade and National Minimum Wage issues but none specifically on Modern Slavery. Therefore, the aim will be to develop a standalone Modern Slavery Policy, outlining the statement of intent on how to manage suspected Modern Slavery and how the University will work with suppliers to ensure any risk is mitigated. This is still under review to ensure it reflects the University strategy and will be completed in 2022.
The University has a Safeguarding Policy along with a Safeguarding team to ensure any concerns around a child or vulnerable adult are raised with the appropriate authorities.
A review of our existing policies will be needed to incorporate our proposed actions.
Our due diligence
In order to prevent Modern Slavery 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 the 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
- A minimum 10% sustainability weighting in tender evaluation criteria is now in place
- In tenders, suppliers will be encouraged to register on NETpositives where it is relevant and proportionate.
- The University is now registered and are using NETpositives to access, review and discuss action plans with suppliers.
- Modern Slavery and Human Trafficking awareness has been introduced as an Agenda item in Procurement Team meetings and in the Fairtrade Steering Group with the possibility of having a separate Modern Slavery Working Group.
- More Fairtrade products have been encouraged within Catering outlets including food, drink and clothing via the Fairtrade Steering Group and have retained the University’s Fairtrade accreditation
- Category Management has been implemented and is moving forward to embed Modern Slavery awareness within all University activities
- Continuation of supply chain mapping, concentrating on the at-risk categories
- Work will continue with local SMEs to encourage them to register and detail an action plan on the Netpostives supplier engagement tool. The target is to double this number from 24 to 48
- Due diligence will be undertaken 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
- Efforts to eradicate practices and issues arising from and affecting Environment, Sustainability, Ethical Business practices, Modern Slavery and Human Trafficking will include staff, students, business partners and suppliers. The Modern Slavery Podcast or e-learning course will assist in this initiative
- The University 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 supply chains and the business, Procurement, along with the University’s 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 are being taken to mitigate these risks. This video will be available for all staff and students, it will be embedded as part of the induction process and training requirements and advertised on the Intranet. The video still is still to be finalised for publication.
Procurement and Purchasing staff have completed the Chartered Institute of Purchasing and Supply’s ‘Ethical Procurement and Supply’ on-line training and will continue to do so on an annual basis.
How we measure effectiveness
Effectiveness will be measured by monitoring how many staff have registered and viewed the Modern Slavery video or completed the e-learning course. Work will continue with the Student Union and Student Experience teams to agree a method of monitoring the effectiveness within the student community.
The University will measure how many additional suppliers register an action plan to combat Modern Slavery on NETpostive
Members of the University’s Governing Council have reviewed this statement and gave its approval of the document 25 January 2022. It was then signed on behalf of Council by the University’s Vice-Chancellor and Chief Executive.
Professor Kathryn Mitchell CBE DL
Vice-Chancellor and Chief Executive, the University of Derby