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É«»¨Ìà 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 É«»¨ÌÃ’s (É«»¨ÌÃ) modern slavery and human trafficking statement for the financial year ending 31st July 2016. This statement has been approved by the É«»¨Ìà Board who, together with the Audit, Risk and Governance (ARG) Committee, will review and update it as necessary on an annual basis.

É«»¨Ìà 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 É«»¨Ìà to achieve this aim.  

É«»¨ÌÃ’s structure

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

É«»¨ÌÃ’s own business

É«»¨ÌÃ’s business as a higher education provider is organised into several Faculties comprising; the Faculty of Health and Social Sciences, the É«»¨Ìà Business School, Faculty of Media and Communication, Faculty of Science and Technology and also the É«»¨Ìà Graduate School. É«»¨Ìà 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. É«»¨Ìà has approximately 17,500 undergraduate and post graduate students who are attracted to É«»¨Ìà from all over the world.

É«»¨Ìà 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, É«»¨Ìà has procedures in place whereby students can obtain support and advice on their wellbeing.

É«»¨Ìà 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, É«»¨Ìà requires that such agencies comply with all UK legislation relating to the employment rights and welfare of candidates. É«»¨Ìà has an Anti-Slavery and Human Trafficking Policy and Procedures providing a reporting mechanism for all staff to raise concerns. In addition, É«»¨Ìà has a Whistleblowing (Disclosure in the Public Interest) Policy. 

É«»¨Ìà supply chains

É«»¨Ìà 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. É«»¨Ìà 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

É«»¨Ìà already has in place a number of frameworks which underpin its ethical standards across all of its business activities. É«»¨Ìà has a Sustainable Procurement Policy to ensure the purchasing of goods and services takes account of their environmental and social impact. É«»¨Ìà 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 É«»¨ÌÃ’s activities.

É«»¨Ìà purchases goods and services via the Crown Commercial Service (CCS). É«»¨Ìà 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 England 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.

É«»¨Ìà policies and due diligence processes for slavery and human trafficking

É«»¨ÌÃ’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 É«»¨ÌÃ’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. É«»¨Ìà 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. É«»¨Ìà also protects whistleblowers via its Whistleblowing (Disclosure in the Public Interest) Policy.  

É«»¨Ìà 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 É«»¨Ìà 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 É«»¨ÌÃ’s values

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

É«»¨Ìà 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 É«»¨ÌÃ’s supply chains and its business, É«»¨Ìà will be providing training to relevant staff.

É«»¨Ìà 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.

É«»¨ÌÃ’s effectiveness in combating slavery and human trafficking

É«»¨Ìà will review the effectiveness of the Policy, training and other measures taken to combat slavery and human trafficking on a periodic basis.