Modern Slavery 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 2021.
The statement sets out the actions the University has taken to combat modern slavery in its supply chains and across its business.
The University of Central Lancashire is a leading modern multi-campus university, in Lancashire, Cumbria and Cyprus. We are 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.
The University’s core business is teaching and research - it has a wide range of subject areas and comprises Faculties and Academic Schools supported by Professional Services teams. We employ around 3000 full and part time staff covering both the Academic and Professional Services areas.
Our newly-formed subsidiary, UCLan Professional Services Limited is a wholly owned subsidiary of the University and is subject in any procurement dealings to the same vetting processes in place for the University, as set out below.
The University has an annual turnover in the region of £250 million of which c£85 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 Procurement & Commercial Services in the delivery of significant procurements and the oversight of contracts management.
The University procures a significant range of goods, works and services across key categories of spend including but not limited to Soft Facilities Management, Construction & Hard Facilities Management, Information, Communications & Technology, Business & Administration Services and Medical Supplies.
The University requires its suppliers and other business partners to have the same high ethical standards in promoting safe and fair working conditions and promoting ethical sourcing within their supply chains. Whilst the University believes the risk of modern slavery in our supply chains is low, our policies and practices are designed to identify and mitigate any risk.
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.
The Procurement team 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 significant. 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
- 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 Procurement, 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.
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, processes and 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 procedures and we are also aware that similar measures have been taken with other public sector frameworks and public sector contracts that we are able to access in order 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% of its overall procurement spend (monetary value) through consortia frameworks.
In order to directly with our suppliers to identify their awareness of modern slavery and human trafficking. We have initiated discussions with 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.
The University has a “Responsible Procurement” Policy that will ensure that decisions taken by the University on the procurement of goods, works or services are undertaken in line with our commitments under the following themes:
- Delivering social value
- Improving environmental sustainability
- Promoting ethical sourcing practices
- Encouraging equality, diversity and inclusion
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.
Our Human Resource Policies ensure that workers are appointed legally, and rigorous checks are carried out on all new appointments both permanent and fixed term including student workers and international researchers. Policies are fully supported by Guidance for Managers. The appointment of temporary or interim resources are approved by the Resources Committee and monitored by both Human Resources and Procurement.
The University has appointed a Director of Equality, Diversity and Inclusion, who will be supported by the Human Resources team in delivering the agenda from the staff perspective. The HR team is responsible for supporting equality and diversity policy development and implementation, and seeks to engage all University staff in promoting a positive and fully inclusive work environment The University gives legal consideration to the requirements of the Equality Act 2010 through an Equality Impact Assessment process by reviewing all the equality impact assessment carried out on the University policies, functions and practices.
The University is committed in its pursuit of academic excellence to equality of opportunity and to a pro-active and inclusive approach to equality, which supports and encourages all under-represented groups, promotes an inclusive culture, and values diversity.
The University spends circa £110 million on goods, services and works per annum including major capital programmes and therefore has a significant opportunity to leverage its supply chain to deliver additional benefits to the University, students, local residents, businesses and communities.
By paying careful attention to how goods, services or works will be delivered, who may be delivering them and what else the supplier can do to deliver added value the University aims to deliver social value, improve environmental sustainability, promote ethical sourcing practices and encourage equality, diversity and inclusion.
All procurements conducted by the University and by those contracted by the University to act on their behalf will do so following the Government Buying Standards ‘Mandatory’ criteria.
To ensure a high level of understanding of the risks of modern slavery in our supply chains, awareness training is completed by Procurement staff.
Material is additionally available on the Intranet to raise awareness of and provide guidance on indicators relating to Modern Slavery.
The University is committed to acquiring goods, services or works without causing harm to others. The University supports the Base Code of the Ethical Trading Initiative. The Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice.
The standards are:
- Employment is freely chosen
- Freedom of association and the right to collective bargaining are respected
- Working conditions are safe and hygienic
- Child labour shall not be used
- Living wages are paid
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.
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.
This Statement has been reviewed by the University's Board and Vice-Chancellor’s Group and will be reviewed at least once annually.
University of Central Lancashire