Modern Slavery and Human Trafficking Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the University's modern slavery and human trafficking statement for the financial year ending 31 July 2018.

The statement sets out the actions the University of Central Lancashire has taken to combat modern slavery in its supply chains and across its business.

About the University

Today the University is one of the UK’s largest universities with a student and staff community approaching 38,000 individuals. Internationally the University has academic partners in all regions of the globe and it is on a world stage that the first class quality of its education was first recognised. The University has an increasingly thriving campus in Cyprus, where it delivers University programmes and original research and provides a University environment and culture.

In 2010, the University became the first UK modern Higher Education institution to appear in the QS World University Rankings. In 2016, the Centre for World University Rankings estimated Central Lancashire to be in the top 3.7 percent of all worldwide universities, highlighting the progress the institution has made in providing students with real-world learning experiences and reflecting the institution’s broad pool of academic talent.

Amongst its programme portfolio of some 400 undergraduate and 200+ postgraduate courses, the University has been at the forefront of developing degrees in emerging disciplines such as Fashion and Forensic Science to an evolving portfolio of Dentistry programmes to meet emerging sector needs. Undergraduate Medicine has now been added to that list, a course being delivered in one of the UK's most modern and inclusive medical schools.
 
The University of Central Lancashire’s core business is teaching and research; it has a wide range of subject areas and comprises 4 Faculties and 20 Academic Schools supported by Professional Services teams. We employ around 1600 full and part time Academic staff and just over 1700 Professional Services staff.
The University has an annual turnover of £226 million of which £72 million is spent on goods and services to support the running of the University with a further £25 million on average on its capital program. The University is supported by a procurement function.

UCLan Business Services Limited is a wholly owned trading subsidiary of the University and is subject in its procurement dealings to the same vetting processes in place for the University, as set out below.

Employment of Staff

The University mitigates the risk of modern slavery occurring in its workforce by ensuring that directly employed staff are recruited by following robust HR recruitment policies. There is a whistleblowing policy in place for members of staff to raise any concerns about wrongdoing by the University.

Staff employed on a temporary basis via agencies are only recruited through established sources who can provide assurance, via the procurement procedures referred to below, that they comply fully with the requirements of legislation relating to the rights and welfare of their candidates and employees.

Procurement

The Procurement team, led by the Director of Procurement, is responsible for managing the University's supply chains.

Procurement spend covers a vast range of goods, services and works and therefore the risk of modern slavery and trafficking is something that is very prominent. The University’s assessment at this time is that the principal areas of the University’s procurement which carry increased risks of modern slavery and human trafficking are:

  • Office supplies
  • Laboratory consumables
  • Garment manufacturing
  • Estates services
  • Construction
  • Cleaning services
  • Security services

It is vital therefore that the University works closely with suppliers in the above categories to understand and assess where items originate from and what conditions the supply chain responsible for these items, are working in. The University, and in particular the Procurement team, is committed to working with suppliers to further develop this knowledge and understanding and assist in improving conditions wherever possible. Early engagement with suppliers and supply chains on any project allows the Procurement team to understand what risks there may be in producing/delivering the requirement and, if necessary, mitigate and eliminate these risks through the competitive tender process.

Policies on slavery and human trafficking

The University is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.  To ensure that this commitment is met in a consistent and appropriate manner the University ensures that modern slavery is addressed within our trading terms.

Due diligence processes for slavery and human trafficking

As part of the University’s initiative to identify, manage and mitigate risk we have in place, along with consortia partners whose purchasing frameworks we use, systems to:

  • Identify and assess potential risk areas in our supply chains
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains
  • Protect whistle-blowers.

These measures are embedded into the University’s policies and procedures and we are also aware that measures have been taken with other public sector frameworks and public sector contracts that we are entitled to use to supply the University.

The University is a member of the North West Universities Purchasing Consortium (NWUPC), which operates under the banner of UK Universities Procurement Consortia (UKUPC), a body dedicated to improving both the quality of procurement and the level of collaborative procurement across the HE sector. Together these consortia have published a shared Sustainability Policy to which all members, including the University, are committed. This policy sets out the steps that must be taken in major contract procurement processes that are conducted for consortium members, to help to ensure that slavery and human trafficking are not occurring in the supply chain. Currently the University spends over 40% (monetary value) through consortia frameworks.

In order to meet our obligations under the act we are utilising an on-line assessment tool that allows us to engage directly with our suppliers to identify their awareness of modern slavery and human trafficking.  We have contacted a number of suppliers to ask about impacts arising from their business activities, including slavery within their supply chains, and providing an opportunity for them to tell us how they are addressing these issues.
The use of the online tool is being made a mandatory part of any contract award where we deem there may be an increased risk of slavery or human trafficking. Review of the action plans developed through the tool will form part of contract management meetings to ensure suppliers are working towards improving conditions within their supply chains. High risk contracts will be prioritised and where required additional due diligence checks take place and if required an audit of the supply chain by the Procurement team would take place.

Supplier adherence to our values

The University has zero tolerance to slavery and human trafficking. Any supplier or potential supplier who does not adhere to our values will be suspended or removed from the University's supplier list and will not be considered for future supply to the University unless they are able to demonstrate full adherence with the requirements of the Modern Slavery Act 2015. Contract clauses around Modern Slavery have been introduced to all UCLan contracts to ensure that should a supplier breach such conditions the University has the right to terminate the contract.

Training

To ensure a high level of understanding of the risks of modern slavery in our supply chains, awareness training is completed by procurement staff.

What we are going to do in the future

Due to the ever changing nature of modern slavery and trafficking the University expresses its commitment to work towards greater transparency on the University's supply chains. This will involve increased collaboration, increased supplier engagement, and increased awareness regarding the risks of modern slavery and trafficking.

Materials will be made available on the intranet to raise awareness of modern slavery and referenced during discussions with requirement owners where relevant.

This statement has been approved by the University's Vice-Chancellor's Group and will be reviewed at least once annually.

The University of Central Lancashire
January 2019

Download a PDF version of our Modern Slavery and Human Trafficking Statement.