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Slavery and Human Trafficking Statement 2024

This is the ninth statement that the ������� (“the University”) has made pursuant to the requirements of the Modern Slavery Act 2015. The University remains fully committed to tackling human trafficking in its supply chains and in all other areas of our activity. In this statement we will provide an update on the actions we committed to achieve in our previous annual statement and, reflecting on our previous activity in this area, we will set out the progress that the University plans to take over the coming twelve months to ensure, as far as possible, that slavery and human trafficking are not taking place in any part of our organisation or our supply chains.

The University’s Structure

The core business of the University is teaching, research and innovation, undertaken by five academic faculties, comprising of their own schools and departments, which are supported by a range of professional services departments. The University is based in �������, but also operates a campus in Walthamstow Central in London.

The University’s Board of Governors is responsible for determining the educational character and mission of the University and for the oversight of its activities. The Board of Governors conducts its work through a number of committees.

The University Executive Board is the senior executive decision-making body of the University. It is chaired by the Vice Chancellor and its membership includes the Executive Deans of each of the University’s five faculties, the Principal of the London Campus, the Senior Deputy Vice Chancellor/Provost, the Deputy Vice Chancellors, the Executive Director of Corporate Governance, the Chief Financial Officer and the Chief People Officer.

The University has approximately 3,600 staff and 31,000 students (this is the total student headcount inclusive of distance learning students and those students registered with collaborative partners). The University is supported by a centralised procurement and contracting function located within professional services with transactional purchasing devolved to individual faculties and professional services departments.

The University is a charity, and is regulated by the Office for Students.

Procurement in the �������

As a public body, the University complies with the Public Contracts Regulations 2015. Our annual external spend is approximately £110 million. The diverse nature of the University’s business and requirements involves dealing with a large number of suppliers, their subcontractors and their supply chains.

The University’s supplier base ranges from cutting-edge scientific/engineering equipment and materials required for the delivery of teaching, research and innovation to the goods, systems and services necessary to support the operation of a successful University. Modern slavery is considered as part of each category or project strategy where appropriate in terms of likelihood of incidence, and any relevant mitigating actions required are identified.

The University conducts a large proportion of its spend via higher education purchasing consortia and other frameworks to which is has access. Doing so means that a) the University can take advantage of specialist procurement staff working within those consortia and b) the buyers acting on behalf of the frameworks can have greater influence on the policy and procedures of their suppliers that individual institutions are able to exert. In particular, the University is a member of, and procures via, the Southern Universities Purchasing Consortium (SUPC). This membership provides the University with access to other higher education purchasing consortia, such as the London Universities Purchasing Consortium (LUPC). Through LUPC the University has access to the services of Electronics Watch which works to protect the rights of electronics workers globally. Overall, the University’s spend via consortia and frameworks was approximately 52%.

The University’s procurement team includes staff who are members of the SUPC/LUPC and HEPA Responsible Procurement Groups, which deal with social and environmental aspects of supply chain management, including moving forward with the modern slavery agenda. Procurement staff are also represented on the University’s Sustainability Strategic Delivery Group set up to deliver against the University’s strategic priorities. Where appropriate to their roles, staff hold procurement professional qualifications and engage with continuous professional development activities. The procurement team is supported by the University Solicitor and the Executive Director of Corporate Governance.

Our policies, procedures and reporting

The University has a number of policies that are relevant to the identification of modern slavery risks and the steps it takes to prevent slavery and human trafficking in its operations. All policies are available to staff on our staff intranet and many are also publicly available online at /about-us/structure-and-governance/policies-and-standards.

Our Instrument of Government, Articles of Government, and our Financial Regulations provide our overarching governance framework.

The Procurement Policy and Procurement Manual set out how we make purchases in compliance with the law and our obligations, include our modern slavery obligations.

Our HR policies and guidance set out our expectations of our staff, and the requirements applicable to recruitment, UKVI compliance, and the use of employment agencies.

The Risk Management Policy sets out the University’s approach to risk management and the mechanisms it employs to identify, analyse and manage risk, including compliance risks and modern slavery risks.

Our Equality, Diversity and Inclusion Policy Statement sets out the University’s commitment to promote fair treatment for all.

The Ethical and Sustainable Investment Statement includes details of the principles we apply when selecting investments.

Our Ethics Policy provides a framework for professional practice and decision-making on ethical issues as they arise in the work of the University.

Our Whistleblowing Policy encourages all our staff, students, contractors, consultants, suppliers, and the general public to report concerns about any aspect of service provision, conduct of officers and others acting on behalf of the University, including our supply chain. The policy is designed to make it easy to make disclosures without fear of discrimination and/or victimisation.

We undertake targeted training on modern slavery and in related areas, such as safeguarding.
Our annual modern slavery statements are reviewed and approved by our Executive Director of Corporate Governance, the University Executive Board, Audit and Risk Committee and our Board of Governors each year. Issues arising in-year are escalated appropriately.

Activities over the last 12 months

In the twelve months to 31 July 2024, we have:

• conducted a review of our recruitment processes in identified at-risk countries, which included updating our recruitment guidelines to ensure compliance with anti-trafficking measures and conducted additional training for our recruitment teams on identifying and mitigating risks of trafficking;

• begun to roll out a communications programme to create awareness amongst staff of how to support students at risk of exploitation and further educate students on the support available to them. In particular:

  • all Designated Safeguarding Leads have attended training that includes specific reference to modern slavery, enhancing their ability to identify and support students at risk;

  • the new safeguarding policy has been published and communicated to all staff via the Staff Newsletter, asking all staff to update their safeguarding training, and wider awareness has been promoted through FESEC committees;

  • we have plans in place to implement a training program for support staff and the wider university community on topics such as safeguarding and sexual misconduct, which will include awareness of exploitation risks; and

  • the creation of the Student Life (Welfare) team provides a new channel for educating students on available support;

• aligned practice across the Corporate Governance and Student Wellbeing services to provide information, safeguarding and reporting options to mitigate any risk of students being trafficked or otherwise abused as workers; including:

  • the establishment of the University Safeguarding Board and the Student Risk & Safeguarding Review Group;

  • the implementation of a centralised system for recording student vulnerability and a working group established to improve data sharing and reporting permitting more aligned practices; and

  • use of a standardised "Raise a Concern" form as a reporting option across the University;

• maintained the close collaborative relationship between the University’s procurement resources and our Corporate Governance function, including UKVI and legal expertise, to improve support available;

• begun the process of updating our standard purchasing terms to align with best practice, particularly in the areas of risk management and compliance (including on modern slavery), alongside a detailed review of our Procurement Policy review, slated for implementation in March 2025; and

• continued to engage with our sector consortia for large, strategic procurement activities, and sharing of best practice with other institutions, particularly in-region.

Activities for the next 12 months

In the next year, we will:

• review training and reporting mechanisms available to staff and students on the risk of exploitation and implement the planned training program for support staff and the wider university community;
• advance the process of updating our standard purchasing terms to align with best practice, particularly in the areas of risk management and compliance (including on modern slavery); and
• deliver a comprehensive review of our Procurement Policy review, and an updated policy for implementation in spring 2025.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the University’s slavery and human trafficking statement for the financial year ending 31 July 2024.