Modern Slavery statement

Introduction

The University recognises that modern slavery is a global issue and is committed to playing its part in supporting its eradication. This statement is published in accordance with the Modern Slavery Act 2015 (the Act) and has been approved by the Audit and Risk Assurance Committee through its delegated power from the Board of Governors. It sets out the steps taken by the University to prevent modern slavery and human trafficking in its business and supply chains.

The University is a Living Wage Employer and does not engage in, or condone, the practices of human trafficking, slavery or forced labour.

Business structure 

The University is a Higher Education Corporation created by an instrument of government issued in April 1993 by the Privy Council.  It is an exempt charity under the Charities Act 2011 and is registered with the Office for Students, the principal regulator for charity law purposes. 

The Board of Governors is responsible for the strategic direction of the University. Our Vice-Chancellor has overall operational responsibility, supported by the Senior Leadership Team. 

Academic Council is the senior consultative committee for academic matters, responsible for providing assurance to the Board and guidance to the Vice-Chancellor. Academic disciplines are organised into four faculties, led by Deans, divided into schools. There are four professional services directorates which includes a central procurement team based in the Finance, Human Resources and Infrastructure Directorate.

The University has the following wholly owned subsidiaries:

• Kingston University Service Company Limited (KUSCO) which provides facilities management services;
• Kingston University Enterprises Limited. The company’s principal activity is the provision of consultancy services;
• KU Holding Limited which is a holding company for its wholly owned subsidiary, KU Student Living Ltd, which is engaged in the maintenance and operation of two University halls of residence.

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 published its own Modern Slavery Statement and through which the University has membership of Electronics Watch which works to protect the rights of electronics workers globally. Our membership of Electronics Watch via the LUPC means we can collaborate to minimise the risks of modern slavery.

The University undertook around 22% of the value of our addressable spend through the London Universities Purchasing Consortium (based on the most recent figures available for the last financial year 23/4) and other collaborative agreements available to the public sector.

The particular business and supply chains which may pose particular risks in terms of slavery are in facilities management, ICT & AV equipment, construction, and partnerships with overseas institutions in some jurisdictions. Our due diligence processes (below) minimise these risks.

Due diligence and compliance

Our procurement process for new suppliers submitting publicly advertised tenders, requires participants, through the standard selection questionnaire, to comply with the Act. We also use a supplier engagement tool (Net Positive Futures) to engage suppliers, requesting that they review and confirm the arrangements they have in place to comply with the Act across their supply chains and key members of the procurement team have received training on use of the tool. 

Through our involvement with the LUPC and other organisations, the team share and keep up to date with best practice to identify and assess risks within supply chains. 

The University and KUSCO do not employ unpaid interns and pay their employees the London Living Wage (or above).  The other subsidiaries have no employees. All centrally tendered contracts reiterate the University’s commitment to fair work practices and paying the real living wage in line with the cost of living. We encourage our suppliers to do the same, pointing them to information about the real living wage.

Our standard terms and conditions of supply and other template agreements include binding obligations to comply with the Act. 

The University’s due diligence processes for the validation of new institutional partners, the renewal of collaborative academic partnerships and all associated agreements, include requirements for compliance with the Act.

All Modern Slavery Statements are published in our annual Financial Statements 

Policies

Our Corporate Social Responsibility Policy and Ethics Statement embeds Modern Slavery considerations, alongside other ethical business practices. They reflect our commitment to the highest standards of ethical conduct in all our activities, along with making continuous improvements in this area.

The University Guide to Good Research Practice incorporates reference to the Ethics Statement and Modern Slavery.

Our Procurement Policy includes consideration of the requirements of the Act.

We encourage the reporting of concerns relating to Modern Slavery and human trafficking. Staff are encouraged to report concerns to their line manager in the first instance. If this is not feasible, or members of the University are unable to do so, concerns should be raised via our Whistleblowing Policy. 

Work will continue during 2025/26 to ensure compliance with the Act.