We recognise that we have a responsibility to proactively work to ensure that all products, goods and services are sourced ethically and sustainably. The University complies fully with EU and UK legislation around procurement activity and is committed to running procurement activities in a way that are fair and transparent.
The University ensures that it maintains the highest standards of integrity and professionalism in its business dealings and practices, and in its decision making around the use of suppliers. The University has built its procurement processes to adhere to 'The 7 principles of public life'.
For the avoidance of doubt, the University also publishes information for suppliers containing the regulation and legislation that applies to all commercial transactions.
Procurement Strategy and regulations
The University Procurement Strategy clearly outlines compliance to the Modern Slavery Act 2015, the University’s commitment to ensuring access to tendering opportunities to local and SME businesses as well as Equality, Diversity, and Accessibility.
The University also signed an agreement to incorporate the UN’s 17 Sustainable Development Goals into its operations in March 2018 which have been built into the 2022-26 Procurement Strategy.
Wherever practical and possible, the University uses competitive and open tender processes and procedures to ensure that it works only with suppliers who:
- Maintain the highest standards of integrity and professionalism
- Follow the requirements of the legislation, including the Modern Slavery Act 2015, the Bribery Act 2010, the WEEE regulations, and other non-obligatory standards where practical
- Adhere to the laws of the countries in which they operate
- Manage their own procurement processes and procedures in such a way that their suppliers in the second-tier supply chain meet the required standards and expectations
There are occasions where, due to the technical or proprietary nature of the requirement (such as specialist scientific equipment, works of art, or unique research) an open tender process may not be possible. These instances are controlled by the Procurement team.
The University has an Environmental Sustainability Team that directly and exclusively focuses on issues related to the environment, sustainability, and other factors including ethical activity by suppliers and the University. All matters relating to the sustainability of the University, including sustainable procurement, are overseen by the Environmental Sustainability Team (EST) made up of representatives from across the University.
The Head of Procurement at the University sits on the HEPA Responsible Procurement Group and the TUCO Sustainability Group both of which address, amongst other matters, any potential human rights abuses in the supply chain, as well as the Environmental Sustainability team meetings inside the University. The University Procurement team has worked closely with SUPC in designing and writing the Accessibility Standards used by SUPC for its Procurement activity.
In addition, the University has employed a student as a paid intern in the Procurement Office who is currently working on a project with the University's largest 300 suppliers by spend, to ensure these suppliers have the correct documentation and proof of compliance to all regulatory and legislatory instruments, including the Modern Slavery Act 2015.
The University published its Sustainable Food Strategy in October 2018. This Strategy aims to reduce the environmental impact of the University’s catering operations, spanning all aspects of sustainable food, including procurement, preparation, provision, food waste and waste management, and education.
Modern Slavery and employment conditions
The University is committed where practical and possible, to ensuring employees in its supply chain are paid the National Living Wage and are not on Zero Hours Contracts.
The University has published a Supplier Code of Conduct that explicitly states: 'The University will not tolerate any instances of Modern Slavery anywhere in its supply chains.'
The University also has a statement in this Code of Conduct that allows unannounced inspections of supplier premises at any time: 'The University of Kent reserves the right to investigate any circumstances relating to any potential breaches of any of the above, including the right to perform unannounced inspections and audits on or off the University campus or at supplier sites as necessary.'
The University also has a Code of Safe Working Practices for suppliers available on the Estates website.
The University has a Modern Slavery Statement on the University's Governance webpages.
Modern Slavery is also addressed in our Terms and Conditions.
Supplier employment conditions
The main consortia the University uses are SUPC, LUPC, TUCO, and CCS. The types of products and services obtained through these Frameworks include (but are not limited to) electronics; PCs; IS hardware such as desktops, laptops, switches, cabling, televisions and projectors; kitchen equipment; food preparation and storage equipment, including commercial freezers; scientific equipment, and similar items.
The Frameworks are awarded through OJEU compliant processes with evaluation criteria including and ensuring suppliers meet all the legislatory and regulatory requirements, including the Modern Slavery Act 2015. The evaluation process for suppliers also includes questions regarding electronic recycling, staff welfare (including where relevant, details of accident records), and ethical supply chain behaviours. IS supply chains are monitored by the Framework providers and it is a contractually binding condition of the Framework that the suppliers operate to the standards set by Electronics Watch.
The University is not directly affiliated with Electronics Watch. However over 80% of the University IS requirements are obtained through Framework contracts established by bodies that have included compliance to the Electronics Watch standards as part of their contractual terms and conditions, and this compliance is checked and vetted as part of the supplier selection process. A further 10% of the IS requirements are in product areas where these requirements would not apply. The University is currently working on projects that will include the remainder inside the Electronics Watch compliant Frameworks.
University suppliers that have been discovered not to comply with the expected standards have either not been successful or had contract awards terminated for breach on at least one occasion since 2016.
The University is satisfied that it ensures that the vast majority of the supply chain it uses is free of abuses of human rights and that it has a sufficient set of controls, checks and balances to identify and investigate any potential abuse or breaches of the legislation, and if necessary terminate contracts with suppliers who are found to be breaching the legislation and / or operating in a way that abuses its workers and / or breaches their rights.
Suppliers to the University may nominate subcontractors to provide some of the requirement, and are expected to declare if any substantial part of the work is to be outsourced. Where this subcontracting is a specialism outside of the supplier's standard area of work this will normally be permitted. The use of subcontractors to evade tax responsibilities is not permitted.
The University may nominate subcontractors that must not be used, for whatever reason that is legal, including poor past performance, evidence of illegal activity such as tax or employment breaches, or where a potential Conflict of Interest (real, or potential) may exist.