Slavery and Human Trafficking Statement
- The University of Bradford is a higher education institution whose objects as set out in its Royal Charter are the “advancement of education and knowledge through teaching and research and the application of knowledge to societal welfare and in particular...teaching and research in technological, scientific, social and professional disciplines…. In addition to its national and international roles it shall have particular commitment to the economic and educational well-being of the city of Bradford and to the district and region”. The University has an annual turnover of approximately £145m, approximately 11,000 students at home and abroad and just over 1,500 staff, with non-pay spend of £53m, of which £37.6m was impactable (i.e. where competition allows the spend can be influenced by procurement). The University is an exempt charity; its registered company number is RC000647.
- Our mission is to drive sustainable social and economic development through outstanding teaching, research and innovation. In delivering this mission the University is committed to being a values-led organisation, with those values including trust as the foundation of our relationships and underpinned by integrity in all that we do. Accordingly, the University is fully committed to employing staff, engaging with and supporting students, acquiring goods, services and works, and otherwise conducting its business in an ethical way and without causing harm to others.
Purpose of statement
- This statement is produced to demonstrate the University’s compliance with Part 6 of the Modern Slavery Act 2015, by informing all members of the University community and other stakeholders about the University’s policies and practices in relation to addressing the risk of modern slavery, human trafficking, forced and bonded labour and labour rights violations in its supply chains.
Structure and Supply Chains
- The University delivers learning, teaching, research and engagement activities in furtherance of its core purposes and strategic objectives and in accordance with its mission, vision and values. These functions, and the underlying organisation, are supported by an array of supporting services and operations. This includes, but is not limited to:
- Academic, professional services and support departments directly employing staff
- External contractors engaged on an ongoing basis to deliver specific functions (e.g. internal and external auditors, catering suppliers)
- External suppliers from whom the University purchases services (e.g. staff recruitment agencies, PR firms, external building contractors, travel services)
- External suppliers from whom the University purchases goods (e.g. stationery suppliers, building suppliers, consumables suppliers)
- External suppliers engaged to carry out work on the University’s behalf or for the benefit of the University (e.g. international student recruitment agents)
- Partnership arrangements with other institutions or organisations which generate a pipeline of student recruitment for the University
- Subsidiary offices operating as recruitment hubs in non-UK jurisdictions (i.e. China office, Dubai office)
- Spin-out companies for commercialisation activity
- In each of these arrangements there is a risk of modern slavery occurring either directly or within the supply chains associated with each of these arrangements.
- The responsibility for identifying and managing the risk of modern slavery within University supply chains sits across the University’s Finance (Procurement) and Governance functions.
- The following procurement categories have been initially identified as higher risk in terms of potential occurrences of modern slavery and human trafficking in the supply chain;
- Science, Technical and Engineering Goods and Services, including laboratory and computing consumables;
- Security Services;
- ICT Equipment and Services;
- Estates/Facilities Goods and Services;
- Stationery and office equipment;
- Uniforms and Clothing;
- Domestic Services
- The University has a zero tolerance policy in relation to modern slavery and human trafficking and the protection of human rights. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure the University is not contributing to modern slavery in any way. In addition to this statement, we have in publication a number of policy statements supporting our commitment:
- Procurement Strategy
- Financial Regulations (incl. Purchasing Policy)
- Employment and HR policies
- Corporate Governance Statement
- Whistleblowing (Public Interest Disclosure) Code of Practice
Contracting for good and services
- The University requires through its Financial Regulations that the University acts ethically in its purchasing activities.
- The Procurement Strategy sets out the strategic institutional approach to procurement and outlines the commitment to obtaining value for money in all of its transactions, and in conducting its daily business staff will consider the institution’s wider responsibilities in terms of legal, moral, social, economic and environmental issues.
- When procuring goods, works and services in the higher risk categories, the University in partnership with sector purchasing consortia, reviews potential suppliers to ensure that they can demonstrate a practical commitment to corporate and social responsibility.
- The University is a member of the North-East Universities Procurement Consortium (NEUPC), which is in turn a member of Procurement England Limited (PEL), the shared vehicle by which English higher education purchasing consortia manage joint developmental and improvement projects for collaborative procurement in the higher education sector. Together, the purchasing consortia have published a shared Sustainability Policy to which all PEL members are committed. The policy forms part of the supplier selection for the major contract procurement processes that are conducted for consortium members, ensuring that slavery and human trafficking are not taking place in the supply chain.
- The University has signed up to NetPositive Futures’ supplier engagement tool which encourages suppliers to engage and develop their Sustainability Action Plans, modern slavery objectives and any other university priorities free of charge. It enables the University to work closely with its preferred and strategic suppliers and allows suppliers to upload their policies and action plans with agreed targets and development schedules.
Other contracting activites
- In agreeing other contracts with external entities, other than through the purchasing system (e.g. recruitment partnership arrangements), the University reviews contractual arrangements to ensure appropriate clauses are included as standard in relation to ensuring compliance with relevant laws, including the Modern Slavery Act 2015.
- The University has robust recruitment and selection procedures and the application of these procedures, together with the Code of Practice on Public Interest Disclosure (Whistleblowing) provides adequate mitigation of risk in relation to directly employed staff.
- The University has established a position whereby all temporary staff are recruited only through selected, established and accredited sources, who can provide assurance of full compliance with all legislative requirements in relation to the rights and welfare of candidates and employees. Specifically, temporary staff are engaged through two possible routes:
- Directly with the University on its own casual worker agreement, they are paid a rate equivalent to the substantive pay grade for the role and are subject to employment rights for the period of any active assignment, and the University’s welfare provisions.
- Through a recruitment agency. These examples are relatively limited, as the University does not have heavy reliance on agency staff. Where the University engages agency staff, it is through an agency who are on a national Higher Education framework whereby they have been assessed through a national procurement process on both quality and cost aspects of their service. Exceptionally, the University will partner with an agency directly who is not on a framework. In these cases, agencies are reputable and well-known, and the University will establish formal contractual agreements with them which set out matters relating to the obligations on the agency to comply with all relevant legislation etc. The University also benefits from having a central temporary staffing team within its People Services team who have oversight of all agency workers and each arrangement in place, to ensure that the relevant standards are being complied with.
- The University’s commitment to workplace rights for employees of the University are outlined in its HR policies available in the University staff intranet. The Whistleblowing (Public Interest Disclosure) Code of Practice is designed to encourage employees to report any concerns which they may have about serious wrongdoing in the University in a responsible and appropriate manner.
- Enforcement of policy standards are managed through the University's Policy Framework which provides for periodic review of policies including:
- when a policy is reviewed in its normal cycle
- when a policy is reviewed as a result of legal or regulatory changes
- when there is a specific internal audit of a policy
- If there is a complaint about the operation of a policy which triggers a review
- If a concern is raised when applying the policy in practice
- Through this process, the policies which form part of the framework for combatting modern slavery are kept under regular review.
- The University maintains a Due Diligence Framework which sets out the ethical and other principles to be considered when undertaking due diligence and upon which due diligence processes for specific activities are based, including for new and existing suppliers.
- Further to this, the University is committed to a better University understanding of its supply chains and will work towards greater transparency in this area in this and future years.
- Through the procurement lead buyer initiative, the University will raise awareness of modern slavery and human trafficking considerations within specific, higher risk procurement categories. These considerations will then form part of the supplier selection process for goods, works and services in these categories.
- Many of our suppliers in the potential higher risk categories outlined above have committed to the Base Code of the Ethical Trading Initiative (ETI) http://www.ethicaltrade.org/eti-base-code and work continues in encouraging and persuading all suppliers in these categories to support these initiatives. The University is also working with local anchor institutions to tackle modern slavery as a wider group, including addressing other sustainability issues, through our joint procurement pledge. The ETI Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice which requires that;
- Employment is freely chosen;
- Freedom of association and the right to collective bargaining are respected;
- Working Conditions are safe and hygienic;
- Child labour shall not be used;
- Living wages are paid;
- Working hours are not excessive;
- No discrimination is practised;
- Regular employment is provided; and
- No harsh or inhumane treatment is allowed.
- Where the University assists students with careers or enters into international partnerships due diligence exercises are carried out by the relevant teams in the University and where appropriate decisions are made by specified committees.
- The University’s Career and Employability Services provides details of part-time and temporary jobs, internships and placements; these opportunities and vacancies are screened to ensure compliance with minimum/living wage criteria for employment which falls within those criteria. The University has a variety of student support and advisory services to enable students to raise concerns. These are actively promoted and signposted throughout the student lifecycle.
- The University is a member of the National Association of Student Employment Services (NASES) and operates within their code of conduct and core values. As a member of NASES we participate in a shared mailing list between HE institutions to warn of vacancies which are suspected scams or from employers who have exploited students. We carry out our own due diligence on vacancies, screening for warning signs which might indicate that the work offered is part of a scam, money laundering scheme, gambling, sex work or other illegal activity. Vacancies for self-employment, commission only work or work for private individuals or where the place of the work is a private residence are not accepted for advertisement on the University vacancies platform.
Risk Assessment and Management
- The University’s risk management framework includes consideration of the risk of modern slavery. This is captured within the procurement, legal and regulatory and people risks, in terms of ensuring adherence of due diligence process, ensuring fair and legal conditions of employment and maintain compliance with our regulatory obligations.
- These risks are kept under review by local departments on an ongoing basis as part of local risk registers and receive detailed scrutiny and oversight through the Risk Oversight Group, reporting through to the University Executive Board and the Audit Committee.
- To mitigate the risk of modern slavery within University operations or supply chains, the Procurement team has continued to update its suite of template contractual documentation and has implemented the use of these templates across all spend values and tender exercises for high risk contracts. This way all suppliers will be under scrutiny, as appropriate to the relevance/risk and spend value, prior to proceeding with purchasing a good or a service.
- Work is ongoing to review incumbent suppliers in high-risk categories for modern slavery and is included in the departmental sustainability workplan as a key deliverable. This activity will tie in with the strategic suppliers engaged via the NetPositive Futures tool.
Effective Action to Address Modern Slavery
- The University will continue to address areas of concern for modern slavery direct in the tendering process through minimum standards, specification and contract management.
- The University will assess the legislation applicable to each contract and takes steps to ensure bidders comply with it.
- The University will review its arrangements for managing modern slavery, and the documentation of these arrangements, against the Ethical Trading Initiative Modern Slavery Statement Framework and will develop an action plan for further activity to ensure that its practice and statement reflect this best practice. This action plan will be developed in the 2022-23 Academic Year, with the completed actions to be reflected in the Modern Slavery Statement 2023, to be approved in November 2023. It will be taken forward in 2022-23 as part of a wider review of the University’s Ethical Framework.
- To date no issues or concerns have been raised which have required action and no incidents have been recorded. However ongoing plans for training, due diligence and risk management may provide further assurance of any suspected unlawful or actual unlawful activity and reporting requirements will be built into policies as a reminder of the need to record reports and take action where necessary.
- The University provides face to face training for relevant staff members on the University’s purchasing regulations and related due diligence processes. This includes consideration of the issue of Modern Slavery as part of this training.
- As part of a wider review of the University’s ethical framework and its anti-corruption, fraud and bribery policies, further training will be delivered to staff on these topics. This training will be adapted to incorporate reference to the Modern Slavery Act and the and the University’s obligations in this regard.
- Any concerns or questions about matters related to this Statement should be addressed to the University Secretary in the first instance.
- This statement has been reviewed and approved by the University’s Executive Board and Council and will be further reviewed on an annual basis.