Modern slavery and human trafficking statement 2022-23

Introduction from the Chief Operating Officer

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain. We are committed to improving our practices to combat slavery and human trafficking.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 July 2023.

Organisational structure

We are a leading UK university in the higher education sector, with a reputation for excellence in teaching and research, strong links with business and industry and unrivalled sporting achievement. The University has over 19,760 students and over 3,600 staff. In 2022/23, we had total income of £379.1 million and total expenditure of £348.7 million.

Loughborough's Chancellor is the formal principal officer. The Chancellor is also an ex-officio member of the University Council and confers degrees on Loughborough’s graduates. The University Council is the governing body, responsible for the University's strategy and overall governance. It is the official emp

loyer of all staff and meets four times a year. Its Chair is the Senior Pro Chancellor, Christine Hodgson. Senate is responsible for the academic work of the University, academic awards, teaching and research quality. Its membership is drawn from the academic staff of the University.

The day-to-day running of the University is the responsibility of the Vice Chancellor and President, Professor Nick Jennings, who is the academic and executive head. The Vice Chancellor works closely with the University Executive Board (UEB) which includes: Deputy Vice-Chancellor and Provost, four Pro Vice Chancellors, the Chief Operating Officer, the Chief Financial Officer, nine School Deans, the Associate Chief Operating Officer and Director of Organisational Development & Change and the Director of Planning & Secretary to UEB. He also works closely with other senior leaders through the University Leadership Group. The University has  9 academic schools,  over 100 research groups, institutes and centres, and 12 professional service functions.

Our supply chains

We categorise our procurement spend as follows: (% split based on 2022-23 spend profile, where total procurement spend was £102m)

University area Indicative percentage split
Estates / Construction 47.8%
Professional Services 18.2%
Laboratory & Medical 9.8%
Travel & Accommodation 5.7%
IT & Telecommunications 5.7%
Catering 4.2%
Miscellaneous 4.1%
Domestic / Cleaning 1.6%
Office Supplies 1.1%
Audio Visual 0.8%
Library 0.7%
Postal Services 0.3%

We have undertaken a high-level risk assessment of our contracts, identifying where supply chains extend into sectors and territories that are high risk in terms of the potential presence of modern slavery. The high-risk sub-categories identified are estates/construction, IT & telecommunications, catering supplies and services, specialist cleaning services, taxis, laboratory supplies (gloves), and personal protective equipment/workwear/sports kit/promotional leisurewear.

Our policies on slavery and human trafficking

Our University Strategy, workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships. We are committed to ensuring that there is no modern slavery in our supply chains, or in any part of our business. Our HR policies and procedures reflect UK employment law.

Our Whistleblowing Policy provides guidance to staff, students, members of its Council and other members of the University on the procedure for the disclosure of information which, in that person’s reasonable belief, is in the public interest and tends to show one or more types of malpractice, impropriety or dangers as specified in the Policy.

The University’s Procurement Regulations require compliance with the Modern Slavery Act 2015 (see clause 1.5. (c)). 

The University’s Sustainable Procurement Guidance Note explicitly references the Modern Slavery Act 2015, with slavery and human trafficking included within the pre-procurement risk assessment tool. It also prompts consideration of the appropriateness of using labour standards (including ILO core conventions) as selection criteria.

Our Ethical Investment Policy includes a commitment to make investments in an ethically responsible manner.

Due diligence processes for slavery and human trafficking

As well as being reflected in our policies and procedures, the requirements of the Modern Slavery Act 2015 are built into our working documents ensuring all tendering exercises undertaken by the Procurement team incorporate the standard modern slavery risk mitigation measures.

The risk of modern slavery within the supply chain is flagged and mitigated within the Procurement Strategy checklist/template, pre-qualification/tender documents and the University’s Standard Terms and Conditions. Our standard tender documents include modern slavery questions enquiring as to bidders’ supply chain risk mapping, contract workforce protections, evidence of modern slavery auditing, follow-up and collaborative action with NGOs and others. Our library of tender questions, to be used where appropriate, covers bidders’ use of recruitment agencies and recruitment fee breakdowns, including confirmation and evidence that the employer pays these fees.

Further to the 2023 Procurement Policy Notice (PPN), mandating amendments to the Selection Criteria (for procurements that fall within the Public Contracts Regulations 2015), we have incorporated the additional (non-mandatory) modern slavery question to ensure a more thorough check on our suppliers.

Our contract summary template, completed by the Procurement Unit/category managers once a contract is awarded, focusing contract managers on the key contract deliverables, performance measures and risks etc., includes modern slavery. We continue to use a number of tools for checking the performance of our suppliers in protecting workers’ rights, including BetterWork for our apparel contracts and Know the Chain for our IT contracts and have a dedicated contract management role to ensure a continued dialogue with suppliers to the University.

We have used NetPositive Futures’ Supplier Engagement Tool to allow our suppliers to access the tool free of charge to create a Sustainability Action Plan for their business. Where relevant, the tool identifies actions for the supplier to take in order to mitigate the risk of modern slavery within its supply chains.

As a founding member of Electronics Watch we are able to build EW labour standards clauses into our contracts for IT hardware, and receive compliance reports from EW monitoring organisations on factories which manufacture products ultimately supplied to the University.

Our pre-qualification/tender documents for Estates procurement signpost the training and resources available from StrongerTogether to help with identifying, and responding to, signs of modern slavery.

The University continues to engage with other universities and higher education purchasing consortia, not least the North Eastern Universities Purchasing Consortium (NEUPC) of which the University is a member, to agree how best our combined resource may be used to identify and monitor risks of modern slavery.

Supplier adherence to our values

We have zero tolerance to modern slavery. As well as taking mitigating measures through the procurement/contract management process (including adding appropriate pre-qualification/tender questions and standard contract clauses), the University expressed this policy, explained the Modern Slavery Act and the related measures we have added to our processes, at local supplier events.

Training

The Procurement team have received Modern Slavery training from NetPositive Futures, the University of Greenwich and the Ethical Trading Initiative. All staff involved in procurement are made aware of the risks and indicators of modern slavery in our supply chains, along with the mitigating measures detailed above, as part of our rolling in-house Procurement training. All staff have been made aware of the free Modern Slavery online training module made available by the British Universities Finance Directors Group (BUFDG). The team will continue to improve awareness of the Act and aim to undertake continual professional development and training.

Combating slavery and human trafficking

Social Value Portal

In 2022-23, we invested in Social Value Portal (SVP) alongside the two other Leicestershire based universities (University of Leicester and De Montfort University), and Leicester City Council, to build measured social value commitments into contracts, then track their delivery during the contract period, with SVP’s support. Of the 37 social value commitments/measures from which bidders can select when tendering, two relate to modern slavery.

Additionally, the University is part of the East Midlands Social Value Task Force.

Living Wage Foundation

The University is now accredited by the Living Wage Foundation, which certifies that all staff are paid a real living wage. Non-University contracted workers that regularly work onsite at the University are expected to be paid the UK living wage as defined by the Living Wage Foundation, and the University evaluates suppliers’ approach to Fair Work Practices, including the Living Wage, in line with statutory guidance.

 

Richard Taylor

Chief Operating Officer
Loughborough University

On behalf of the Council of Loughborough University which approved this statement on 23 November 2023