Modern slavery and human trafficking statement 2017-18
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 in order to exploit them for personal or commercial gain.
We are committed to ensuring our practices do not support organisations or individuals who engage in 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 31st July 2018.
We are a leading UK university, with a reputation for excellence in teaching and research, strong links with business and industry and unrivalled sporting achievement. The University has over 17,000 students and over 3,500 staff. In 2017-18, we had total income of £300.8 million and total expenditure of £295.5 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 day-to-day running of the University is the responsibility of the Vice Chancellor and President, Prof Robert Allison, who is the academic and executive head.
The Vice Chancellor works closely with the Academic Leadership Team which includes: the Provost and Deputy Vice Chancellor, three Pro Vice Chancellors, the Chief Operating Officer, the Director of Finance and ten School Deans. He also works closely with other senior officers.
The University Council is the governing body, responsible for the University's strategy and overall governance. It is the official employer of all staff and meets four times a year. Its Chair is the Senior Pro Chancellor, Sir Peter Bonfield.
The University 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.
Our supply chains
We categorise our procurement spend as follows: (The percentage split is indicative)
|University area||Indicative percentage split|
|IT & Telecommunications||7.4%|
|Laboratory & Medical||7.1%|
|Travel & Accommodation||4.1%|
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-hardware, catering supplies and services, laboratory supplies 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.
The University’s Procurement Regulations require compliance with the Modern Slavery Act 2015.
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.
As a member of Electronics Watch the University can build EW labour standards clauses into its contracts for IT hardware and receive compliance reports from EW monitoring organisations on factories which manufacture products ultimately supplied to the University.
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. 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.
The University has purchased NetPositive Futures’ Supplier Engagement Tool, which means our suppliers can 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. The tool allows the University to run reports to see individual supplier’s/all registered suppliers’ progress against the identified actions within their plan(s). The University’s template contract award letter encourages suppliers to use the tool.
Furthermore, our contract summary template, which is 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 a modern slavery risk rating. The contract summary template also notes the availability of NetPositive action plan progress reports, including the supplier’s progress in taking forward any modern slavery mitigation actions.
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 review/monitor risks of modern slavery in our supply chains.
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.
The Procurement Unit has received Modern Slavery training, from both the University of Greenwich and the Ethical Trading Initiative. To ensure a high level of understanding of the risks and indicators of modern slavery in our supply chains, we identify them in our rolling in-house Procurement training, along with the mitigating measures detailed above.
Our effectiveness in combating slavery and human trafficking
All tendering exercises undertaken by the Procurement team during 2017/18 incorporated the standard modern slavery risk mitigating measures now built into our procurement process/working documents. For high risk contracts (flagged at procurement strategy stage), further checks were included:
- Computer hardware (excl. Apple products), where Electronics Watch labour standards clauses (explained above) were included
- Pods refresh, where Electronics Watch labour standards clauses (explained above) were included
- Workwear, where extra tender questions were added with a 5% overall weighting
- Sports kit, where extra tender questions were added
The need for further slavery checks has also been established for several planned, upcoming tender exercises for high risk contracts, including for a Minor Works framework agreement, and contracts for furniture, laundry services, deep cleaning of student residences, stores supplies and white goods. It has also been determined that further checks need building into existing high-risk contracts, including Apple computer products, personal protective equipment, catering supplies and courier services contracts. The decision has been taken to make the creation and maintenance of a NetPositive action plan (explained above) a contractual requirement for a number of these high risk contracts.
Chief Operating Officer
On behalf of the Council of Loughborough University which approved this statement on 22nd November 2018