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Statement on the Modern Slavery Act

Introduction

This Statement is designed to satisfy the requirements of Part 6 Section 54 of the Modern Slavery Act (2015).

The University's Ethics Policy states our commitment to the highest standards of ethical conduct in all our activities, along with making continuous improvements in this area. The University does not engage in, or condone, the practices of human trafficking, slavery or forced labour.

Structure of the business and supply chains

The University's supply chains mainly fall within the following ‘top level' categories:

  • Estates and facilities management (works, services and goods)
  • ICT equipment and services
  • Professional services
  • Teaching materials

The University is a member of the London Universities Purchasing Consortium (LUPC) which has also published its own Modern Slavery Statement. We channel in excess of 30% of the value of our addressable spend through LUPC and agreements arranged by the other higher education purchasing consortia and public sector purchasing consortia. The particular business and supply chains which may pose particular risks in terms of slavery are in facilities management, ICT and AV equipment, construction, and partnerships with overseas institutions in some jurisdictions. Our due diligence processes (below) minimise these risks, and our facilities management services are provided by our wholly owned subsidiary, which pays the London Living Wage.

Policies

The University has put in place a number of measures to ensure compliance with the Modern Slavery Act 2015.  Our draft Ethics Strategy will embed Modern Slavery considerations, alongside other ethical business practices. The University Guide to Good Research Practice is also under review and will incorporate reference to the Ethics Strategy and Modern Slavery. Training in relation to the Ethics Strategy (including Modern Slavery) will be provided once that Strategy has been formally approved.

Due diligence

Our due diligence process for the validation of new partners, and arising institutional agreements, include requirements for compliance with the Act. Additionally, we use a procurement tool where all new suppliers are requested to complete a questionnaire to confirm arrangements in place across supply chains. We also undertake much of our procurement via the London Universities Purchasing Consortium which itself has publicly committed to  tackling slavery and human rights abuses in its supply chains, and to acquiring goods and services for its members without causing harm to others. The University also has a policy of not employing unpaid interns across the facilities management workforce.

Work will continue during 2016/17 to ensure compliance with the Act.

Matthew Hilton 
Deputy Vice-Chancellor (University Secretary and Chief Operating Officer)
November 2016

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Kingston University
Tel: +44 (0)20 8417 9000

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