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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 Act).

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 and through whom the University has membership of Electronics Watch which works to protect the rights of electronics workers globally. The University undertakes 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 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.

Due diligence

Our due diligence process for the validation of new institutional partners, and arising agreements, includes requirements for compliance with the Act. Our procurement process for new suppliers uses EU level tenders, requiring participants through the standard questionnaire to comply with the Act. We also use a supplier engagement tool (Net Positive Futures) to engage suppliers, requesting them to review and confirm arrangements they have in place to comply with the Act across supply chains. All members of the procurement team have received training on use of the tool. Through our involvement with LUPC and other organisations, the team share and keep up-to-date with best practice to identify and assess risks within supply chains

Our facilities management services are provided by our wholly owned subsidiary, which pays the London Living Wage and does not employ unpaid interns. Our membership of Electronics Watch via the LUPC means we can collaborate to minimise the risks of modern slavery.

Policies

The University has put in place a number of measures to ensure compliance with the Modern Slavery Act 2015. Our Corporate Social Responsibility Policy and Ethics Statement embeds Modern Slavery considerations, alongside other ethical business practices. The University Guide to Good Research Practice incorporates reference to the Ethics Statement and Modern Slavery. Training in relation to the Ethics Statement (including Modern Slavery) is provided.

Work will continue during 2019/20 to ensure compliance with the Act.

Keith Brennan
Registrar and University Secretary
September 2019

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Tel: +44 (0)20 8417 9000

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