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Slavery and Human Trafficking Statement

December 2019

Introduction

  1. 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 £109 million, approximately 9,000 students at home and abroad and just over 1,500 staff and purchases approximately £37.7 million per annum of goods, services and works through a variety of supply chain arrangements. The University is an exempt charity; its registered company number is RC000647.
  1. The University’s values, as outlined in its 2015-25 Strategic Plan, include the application of the best ethical standards in everything that we do. Accordingly, the University is 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. The University is committed to supporting the UK Government’s approach to implementing the Guiding Principles on Business and Human Rights.

Purpose of statement

  1. 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 policy in relation to modern slavery, human trafficking, forced and bonded labour and labour rights violations in its supply chains.

Structure and Supply Chains

  1. The University’s supply chain has been identified as the area of highest risk in terms of possible occurrences of modern slavery and this sub-section sets out the mitigating actions that have been taken or are planned.
  2. 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;
    • Construction;
    • Catering;
    • Stationery and office equipment;
    • Uniforms and Clothing;
    • Domestic Services.
  3. 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.
  4. As part of its action plan for 2018/19 the University signed up to NetPositive Futures’ supplier engagement tool in December 2018 for a two-year term. The software is funded by HEIs to encourage 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.

Policies

  1. The University has a zero tolerance 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. We have in publication a number of policy statements supporting our commitment:
    • Corporate Governance Statement
    • Whistleblowing (Public Interest Disclosure) Code of Practice
    • Procurement Strategy
    • Purchasing Policy
    • Financial Purchasing Regulations
    1. 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.
    2. The University requires through its Financial Purchasing Regulations that the University acts ethically in its purchasing activities.
    3. 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.
    4. 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 3 consortium members, ensuring that slavery and human trafficking are not taking place in the supply chain.
    5. During the course of the coming year it will carry out a more focused review of its policies as part of its due diligence, assurance and risk management activities. It will particularly focus on ensuring that its policies in the following area make clear and unambiguous reference to the requirements of the Modern Slavery Act 2015 and the University’s commitment to the objectives of the Act.
    6. 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

    Due dilligence

    1. 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.
    2. The University will map its suppliers, with the support of external specialist organisations, such as the purchasing consortia, Electronics Watch and People and Planet. It will build on the initial assessment outlined in paragraph 10 above, in order to identify supply chains in which there is a significant potential risk of modern slavery, human trafficking, forced and bonded labour and labour rights violations. Following such monitoring, appropriate action will be taken where necessary.
    3. 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.
    4. 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 we will be working to persuade all suppliers in these categories to support these initiatives. 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;
    1. Employment is freely chosen;
    2. Freedom of association and the right to collective bargaining are respected;
    3. Working Conditions are safe and hygienic;
    4. Child labour shall not be used;
    5. Living wages are paid;
    6. Working hours are not excessive;
    7. No discrimination is practised;
    8. Regular employment is provided; and
    9. No harsh or inhumane treatment is allowed.
    1. The University has reviewed its key performance indicators in line with Home Office guidance and work is ongoing to develop these within this statement. It has also reviewed its business structures and due diligence processes for incorporation within this statement.
    2. 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.
    3. 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.
    4. 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

    1. The University has established a due diligence framework setting out the matters that the University should take into account when entering into difference relationships with suppliers and other University partners and stakeholders. During this year, the University will be working with specific operational areas to update due diligence processes in accordance with the principles et out in this framework.
    2. Agreements which do not come within the commercial contracts supply chain dealt with by the procurement team and which are dealt with by the legal services team are reviewed and terms and conditions are included where appropriate for example in standard or ad hoc international recruitment and education related agreements. These are not considered to be high risk.
    3. Where international partnerships are entered into a separate due diligence exercise is carried out and site visits made to the oversea institutions.
    4. 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 is working towards 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.
    5. To mitigate the risk of modern slavery being overlooked, in all its forms, procurement has recontinued to update its suite of template contractual documentation and will be implementing the use across all spend values and tender exercises for high risk contracts. This way all suppliers will be 5 under scrutiny, as appropriate to the relevance/risk and spend value, prior to proceeding with purchasing a good or a service. In addition, a review of incumbent high-risk modern slavery suppliers to the university is included in the departmental workplan with a view to completion by the end of March 2020. This activity will tie in with the strategic suppliers engaged via the Netpositive Futures tool.

    Effective Action to Address Modern Slavery

    1. The University will continue to address areas of concern for modern slavery direct in the tendering process through minimum standards, specification and contract management.
    2. The University assesses the legislation applicable to each contract and takes steps to ensure bidders comply with it e.g. Health and Safety Legislation.
    3. 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.

    Training

    1. The University assessed and developed an online training tool, but it has now assessed and identified face to face training for targeted areas which will prove more effective particularly in relation to targeted risk areas. This will sit alongside general training and awareness raising measures in relation to modern slavery and this includes those staff identified in paragraph 6 above.

    Further Information

    1. Any concerns or questions about matters related to this Statement should be addressed to the University Secretary in the first instance.
    2. This statement has been reviewed and approved by the University’s Executive Board and Council and will be further reviewed on an annual basis.