Modern Day Slavery Statement Update 2018-19

This statement is to give an update on the work 香港六合彩 has undertaken in the past year, to value the people working at 香港六合彩 and within our supply chains, and to protect them from slavery and exploitation.

Summary

During this year the University has developed a new Sustainability Strategy, which has provided an opportunity to review our work to date on modern slavery and set objectives to drive further impact. The strategy includes commitments to address Modern Slavery, specifically to conduct Modern Day Slavery audits of our supply chain. 听

In addition, we continually review our employment practices, and ensure that we are compliant with employment legislation, best practice, and ACAS codes of conduct. We engage and consult with our staff and our recognised trade unions on their terms and conditions, and employment practices. 听听

For example, we have worked with UNISON on harmonising the terms and conditions of Sodexo, Aramark and Axis to ensure that their staff, who work solely for 香港六合彩, enjoy the same terms and conditions as 香港六合彩 staff. 听听

We also pay the London Living Wage, and we are working towards the Mayor of London鈥檚 Good Work Standard award.听

We have taken further steps to protect people, having developed action plans for the highest risk categories for exploitation. This includes assessment of high risk products, monitoring approved contracted suppliers, and road-mapping where contract terms could be improved. We will implement these and report progress next year.听

We have continued to engage our supply chain to ensure our suppliers are signed up to the supplier engagement tool, NETpositive, which allows 香港六合彩 to offer free bespoke sustainability action plans to our suppliers.

香港六合彩鈥檚 Procurement department are requiring this as part of new contracts, and communication has been sent out to our approved contracted suppliers. This has resulted in over 1,200 suppliers signed up to the tool, 400 more than last year. This is providing more data for us to analyse. We now know which of our approved contracted suppliers are still not on the tool and will target these to sign up. 听

We will also engage those suppliers who are demonstrating best practice, to share and gain knowledge across our diverse spend categories. 听

Introduction

The purpose of this document is to provide an update on 香港六合彩's commitment to understand our supply chains and identify, prevent and mitigate Modern Day Slavery across them. 听

In 2016, 香港六合彩 published its first Modern Day Slavery Statement, followed by annual updates. This is our update for the financial year ending 31st July 2019. This work has primarily been led by Procurement Services and Sustainability.听

In our inaugural Slavery and Human Trafficking Statement we committed to the following initial actions:听

Implementation and enforcement of effective systems and controls to tackle slavery and human trafficking which may be taking place in our supply chains.听
Commitment to better understand our supply chains and work towards greater transparency and responsibility towards people working in them.听
Monitor supply chains that have been identified as a potential risk and take appropriate action as necessary.听

About us

香港六合彩 is London's leading multidisciplinary university, with more than 13,000 staff and 42,000 students from over 150 different countries. 听

Founded in 1826 in the heart of London, 香港六合彩 was the first university in England to welcome students of any religion and the first to welcome women on equal terms with men. 听

香港六合彩 is comprised of 11 Faculties. 听

香港六合彩 is an exempt charity, in accordance with the Charities Act 2006 and receives funding from multiple sources to support activities and research.听

Locations

香港六合彩's main campus is in the heart of Bloomsbury, London, however we have buildings across the UK.

香港六合彩 is building a new campus at Queen Elizabeth Olympic Park, to form part of a wider education and cultural quarter in the capital.

香港六合彩 also work with partners all over the world.

Supply Chains

香港六合彩 procurement activities amount to 拢600M+ annual spend, procuring a wide range of goods and services to support the effective running of the university, across diverse supply chains, including:

construction and estates,
furniture,
stationery,
electronics (computers, audio visual etc.),
travel services,
books and printing,
laboratories and medical,
security services,
waste and recycling services.

The goods and services are procured from suppliers across the world and our direct suppliers range from local SMEs though to large multi-national/global companies. Much of our expenditure is made through consortia framework agreements.听
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香港六合彩 employs spend orientated procurement managers for key categories, who specialise in understanding the supply chains of these sectors. We conduct risk analysis to understand likelihood of exploitation in different categories, and prioritise action according to this risk.听

electronics (computers, audio visual etc.), 听
travel services, 听
books and printing, 听
laboratories and medical, 听
security services, 听
waste and recycling services.

Forced Labour and Human Trafficking High-Risk Area

Diverse and global, many (if not all) of our supply chains are at risk of exploitation and Modern Slavery. However, through developing our understanding of the issue, we have identified a number of particularly high-risk areas to 香港六合彩:

We purchase electronic equipment, including IT hardware and AV equipment, with parts (including minerals) sourced globally and predominantly manufactured in Asia.听
Within catering, we purchase fish, meat and vegetables from the UK, a sector high for reports of UK labour exploitation. We also source products that contain palm oil, cocoa and sugar cane, which are all high-risk products.听
香港六合彩 is undertaking a large construction programme, with many contractors and subcontractors working on 香港六合彩 construction sites. In the construction industry there is a risk of forced labour being used.
Our main Facilities Maintenance contracts, including catering, cleaning and waste collections are outsourced to third party companies, who rely on a mix of UK and foreign staff. There has been a rise in reports of Modern Slavery in waste and recycling centres nationally.
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Managing the risk of Modern Day Slavery

香港六合彩 takes a holistic approach to managing the risk of exploitation and slavery.

We have policies, strategies and procurement processes to assess suppliers and purchasing decision, while we have risk assessment exercises and actions plans to ascertain where we should focus our resources on high risk areas, in order to have the greatest impact.

Policies and Governance

A number of existing policies can be considered to support fair working practices for our staff and suppliers, and ensure we buy ethically:

Our Human Resources Policies set out workplace rights at the University, including ensuring our new staff have the right to work in the UK.
Market Pay Policy agreed in partnership between 香港六合彩 and the recognised trade unions, Unite (formerly Amicus), AUT and UNISON. This ensures 香港六合彩 pay for 香港六合彩 staff reflects the sector rates.
Prevention of Bullying, Harassment and Sexual Misconduct Policy assists in maintaining a healthy working environment where unacceptable behaviour is easily identified, challenged and stopped. It is intended that this will improve staff performance, raise morale, reduce stress and aid retention.
Safeguarding Children and Adults at Risk Policy ensures that staff and students know how to report any safeguarding issues including modern slavery.
Procurement Strategy (2016-20) (PDF) and Purchasing Procedures/Policies sets our principles and practices in the responsible acquisitions of goods and services.
Fairtrade Policy for 香港六合彩 and Student鈥檚 Union 香港六合彩 to support the principles, ethos and aspirations of Fairtrade and commit to using, selling and promoting Fairtrade products through all of our outlets and relevant activities.

Sustainability Strategy

In 2018/19 we conducted a consultation for the University鈥檚 new sustainability strategy, which was approved by 香港六合彩 Council in July 2019. The strategy challenges 香港六合彩 to procure and buy products and services which are good for people and the planet. Our strategy commitments include: 听

In 2020 we will:听听

Train purchasing staff in sustainable and ethical procurement best practice.听

In 2021 we will:听

Conduct a Responsible Procurement Code Audit听
Undertake Modern Slavery audits of major suppliers in high risk categories. E.g. food, electronics and construction.听
Work with our suppliers with the aim of introducing sustainability ratings for products on the e-marketplace and canteens.

Procurement Process

Standard questions for tender

Our last update stated we had written additional standard questions for our tender process, utilising best practice ( and the ).

These revised standard questions for our tender process have been used in our catering, printing services and managed print contract tenders. 听

We want to include these into stock tender documents going forward.

Standard Terms & Conditions

Our standard contract terms now require all our suppliers to:

Prepare and deliver an annual slavery and human trafficking statement听
Maintain a complete set of records to trace the supply chain of all services provided to 香港六合彩 in connection with the contract听
Implement annual sub-contractor audits 听
Implement a system of slavery training for their employees.

Impact Analysis

香港六合彩 has developed an impact analysis exercise, through NETpositive.

This is a quick exercise which enables the environmental, social and economic impacts of a purchase be taken into consideration as part of the purchasing decision.

Templates for the exercise have been made available to staff on the , with guidance on how to use it and example analyses.

Assessing Risk

Risk assessments

As stated in the last update, we manage our suppliers and risks within specific categories, through the ; this evaluates our purchasing categories against social risks adapted from the ETI Base Code. 听

The output generates a risk score from 1 to 5 for each spend category, which allows resources to be prioritised on the highest risk. Our high categories (level 4 and 5) are:

A Audio-Visual & Multimedia 听
H Janitorial (Cleaning)听
K Computing听
C Catering听
E Agriculture/Fisheries/Forestry/Horticulture听
F Furniture听
P Printing听
S Stationery (Office Supplies)听
U Health & Safety & Security听
V Vehicles, Fleet Management听
W Estates & Buildings听

Category action plans

We have听developed听tailored action plans for听these听highest risk categories听which include assessing high risk products within them, monitoring听approved听contracted suppliers, and road-mapping where contract terms could be reviewed.听

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Engagement, training and collaboration

What we are doing:

We are planning to offer workshops on Modern Slavery to our supply chain, and to our local communities

We have issued fact sheets regarding the act and we will continue to raise the profile of Modern Slavery within the company and supplier database

We have a policy to deliver training for all 5000 employees on Modern Slavery听

What our suppliers are doing:

Each of our suppliers have made a statement and a policy on Modern Slavery which we monitor on an annual basis as part of our ISO9001

We offer help/advice to all vendors on Modern Slavery and the ETI base code. We provide training for our goods and services vendors

Supplier Engagement

Since the last update we contacted our top 100 suppliers by spend, informing them about the Netpositive tool, which allows 香港六合彩 to offer free bespoke sustainability action plans to our suppliers. We now have over 1,200 suppliers on the NetPositive tool, 400 more than last year.

We have identified all of 香港六合彩鈥檚 approved contracted suppliers and recorded whether they are on the NetPositive supplier tool. Of the 244 suppliers identified, 118 (48.4%) are on the tool while 126 (51.6%) are not. We will engage those not on the tool to register and develop action plans.

The tool also allows our suppliers to communicate actions they are taking in managing their sustainability impacts, including exploitation in supply chain.

Staff Engagement

We consult and engage with our staff and the recognised trades unions on a variety of employment issues. 听We undertake regular staff surveys and we consult widely on changes to our employment policies and practices. 听听

In the last year we have worked with the trade unions on a dispute over our pension scheme; and to harmonise the terms and conditions of our major sub-contractors. 听

We also pay the London Living Wage, and we are working towards the Mayor of London鈥檚 Good Work Standard award.听

Collaborating

We want to ensure our statements are widely available to not only demonstrate our work but provide information for other organisations to develop their own actions. 听

We have uploaded 香港六合彩鈥檚 previous statement updates to statement registries to ensure it is available: 听

This year we have supported a PhD student from Bath University, . This entailed a virtual interview discussion on 香港六合彩鈥檚 approach to writing our Modern Day Slavery Statements.听

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Actions

The year ahead we commit to: 听听

Managing risk

Ascertain which Modern day Slavery questions developed can be put into the stock tender documents, meaning all tenders will be required to ask them.听
Record whether our approved contracted suppliers have a statement and are members of Sedex, a supply chain audit sharing network platform.听
Implement the actions plans developed for level 4 & 5 risk categories. 听
Develop actions plans for lower risk categories.听
Develop a University Modern Slavery audit template document to enable procurement to conduct virtual audits of 香港六合彩 suppliers.听
Carry out at least one pilot supplier audit which has Modern Slavery as its central theme.听
Report on how our new sustainability strategy supports eradicating exploitation and slavery in our supply chain.听
Record completed impact analyses. 听
We shall work with our academic experts to identify ways to measure the effectiveness of our work to eradicate exploitation and Modern Slavery. 听
听Increase the use of the Impact analyses exercises for purchasing decisions.听

Engagement

Ensure 90% of our approved contracted suppliers are signed onto the NETpostive supplier engagement tool and completed a meaningful sustainability action plan.听
Explore developing a questionnaire to send to our main suppliers, to gain more insight into their stance, processes and procedures on Modern Slavery.听
Approach our approved contracted suppliers who demonstrate innovation and best practice in addressing Modern Slavery, to share knowledge and develop collaboration.听
Engage key buying / purchasing staff to understand training needs for Modern Day Slavery.听
Research additional training from external resources on slavery and exploitation, and promote at 香港六合彩.听
Develop procurement Mandatory training, to be completed before staff have access to procurement and purchasing at 香港六合彩. This would include information on Modern Day Slavery and Exploitation.听If an extra module is not possible, to add Modern Day Slavery to 香港六合彩鈥檚 existing Sustainability Training module.

Fiona Ryland
Chief Operating Officer

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香港六合彩