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 2019 to 31 July 2020.
Introduction
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.
Organisational structure
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 of 2019/2020, we had an annual turnover of £193.8m.
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 2,500 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, for risk or high-value contracts, to 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. This can be used to track the actions being taken and progress being made by our supply chain in addressing aspects of modern slavery.
32.58% of our suppliers have signed up to NETpostive by the end of July 2020 and, of those 831 suppliers, 97% are aware of the Modern Slavery Act and 32% have confirmed that they have made a public commitment to Modern Slavery. 13% of the University’s suppliers with action plans on NETpositive confirm that they engage with their own supplier on Modern Slavery and 13% engage in Modern Slavery training within their organisations.
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
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:
- Catering
- Cleaning services
- Security
- Capital building projects – construction workers
- Clothing
- Furniture
- IT
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.
Due to COVID-19, we have not been able to undertake the supply-chain-mapping exercise to Tier 3. Our future focus is on selecting a small number of suppliers to map their supply chain to source, which will highlight if we are purchasing from countries which have the highest rates of modern slavery. This will enable us to develop a risk mitigation strategy jointly with our suppliers.
Our policies
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. Due to COVID-19, this has been delayed and will be developed in 2021.
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 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
- A minimum 10% sustainability weighting in tender evaluation criteria is now in place
- In our tenders we will encourage all suppliers to register on NETpositives where it is relevant and proportionate
- We are now registered and are using NETpositives to access, review and discuss action plans with suppliers
- We have introduced 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 and have retained our Fairtrade accreditation
- 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
Training
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 advertised on our intranet pages. Due to COVID-19, the video has not been finalised but will be available mid-2021.
Procurement and Purchasing staff have completed the Chartered Institute of Purchasing and Supply’s ‘Ethical Procurement and Supply’ online training and will continue to do so 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. Due to COVID-19, this has not been possible so will be carried forward to 2021.
We 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 the Council gave its approval of the document 26 January 2021. It was then signed on behalf of Council by the University’s Vice-Chancellor and Chief Executive.
Signed by:
Professor Kathryn Mitchell BSc, PhD, CPsychol
Vice-Chancellor and Chief Executive, the University of Derby