Modern Slavery Act 2015 - Modern slavery and human trafficking statement
At its meeting on 27 November 2018 Council considered a Modern slavery and human trafficking statement and authorised the Chair of Council to sign the statement on its behalf. Prior to its consideration by Council the statement was considered by Executive Group (the Vice-Chancellor and President's executive committee responsible for the day to day running of the University).
The following is the approved statement which was signed by Sir David Warren, Chair of Council, January 2019.
Modern Slavery and Human Trafficking Statement
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.
The University of Kent is committed to ensuring that there is no modern slavery or human trafficking in its supply chains, corporate activities or in any part of its business, and is reviewing its workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.
The University of Kent is an exempt charity regulated by the Office for Students on behalf of the Charity Commission for England and Wales. The University’s Royal Charter of 1965 established the University Council as the supreme governing body of the institution. The University Council serves as the University's board of trustees and has overall responsibility for the University's strategic aims and direction in the furtherance of the objects defined by the Charter.
From the Royal Charter, the objects of the University are;
“to advance education and disseminate knowledge by teaching, scholarship and research for the public benefit.”
The University has an annual income of £267.1m (financial year end 31 July 2017), has 6216 employees and, as well as campuses in Canterbury and at Medway within the UK, the University of Kent has specialist postgraduate centres in four European capital cities: Athens, Brussels, Paris and Rome.
A central Procurement team has been established at the University. The team is reviewing all processes and procedures, including those around selecting and managing suppliers, to make sure that they comply with the requirements of the Act.
The University has devolved purchasing in its Schools and Professional Service Departments and buys a wide range of goods and services, from research equipment to food items. The central Procurement team will be working with all areas of devolved purchasing activity so that they are aware of the requirements in selecting and working with suppliers.
Policies on slavery and human trafficking
The University of Kent is reviewing its workplace policies and procedures to ensure that they adhere to the University’s commitment to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to minimise the risk of slavery and human trafficking taking place anywhere in the University’s supply chains.
The University has updated its external website with information regarding modern slavery and information around legislative and regulatory compliance: https://www.kent.ac.uk/finance/procurement/index.html
The University has the following existing policies that help to minimise the risk of modern slavery and human trafficking in its operations:
Whistleblowing Policy - The University encourages all of its workers, customers and other business partners to report any concerns related to the direct acvities or the supply chains of the organisation. This includes any circumstances that might give rise to an enhanced risk of slavery or human trafficking. The University's Whistleblowing Policy is designed to make it easy for workesr to make disclosures, without fear of retaliation.
Code of Conduct - The University's employee Code of Conduct makes clear to employees the actions and behaviour expected of them when representing the organisation. the University strives to maintain the highest standards of employee coduct and ethical behaviour when operating both at home and overseas, and in managing its supply chain.
Recruitment Procedures - The University's Recruitment Procedures ensure that the recruitment of new employees is in line with a consistent and transparent process that requires corporate oversight and approval. All chairs of recruitment panels are trained to ensure that workers are appointed to authorised roles in line with corporate terms and conditions.
The University of Kent’s supply chain include a total of 3139 separate suppliers across all of the requirements of the University. The University has been standardising its methods for procuring goods and services by extending the use of IT (Agresso Purchase Order Processing) to facilitate compliance with EU and UK regulations. A training programme has been provided for purchasers that has resulted in a significant reduction in manual payments and an improvement in management information.
The University is mapping its supply chain, identifying areas of risk and will act appropriately in cases where abuses are found.
The University works with a number of collaborative professional buying organisations such as Crown Commercial Services (CCS), The University Caterers Organisation (TUCO) and is a member of the Southern Universities Purchasing Consortium (SUPC).
SUPC is a member of Electronics Watch, and its Modern Slavery statement is available on its website: https://www.supc.ac.uk/about-us/sustainability
The University also works with the Higher Education Procurement Association (HEPA) and institutions across the sector, being a member of HEPA's Responsible Procurement Group.
Due diligence processes for slavery and human trafficking
The University is preparing new systems and processes to:
- Identify, assess and monitor potential risk areas in its supply chains, considering specific categories and requirements that may have higher potential exposure to the requirements of the Modern Slavery Act, such as IT and electrical recycling, food supply services and construction;
- Mitigate the risk of slavery and human trafficking occurring in its supply chains;
- Ensure that equipment disposal is executed in an ethical manner.
Supplier adherence to the University’s values
The University has zero tolerance to slavery and human trafficking and will not support or deal with any business or institution knowingly involved in modern slavery practices in any part of its operations.
The Procurement team has integrated clauses into its Terms and Conditions documents, and a requirement into its potential supplier evaluation criteria, to ensure that suppliers to the University adhere to the requirements of the Modern Slavery Act and have responsble and sustainable supply chains. Suppliers that do not adhere to this will be deselected and not used by the University.
To ensure that all suppliers in the University’s supply chain and contractors, subcontractors and the manufacturers of supplied goods, comply with the University’s values, a supply chain compliance programme is being prepared and implemented and the supplier vetting programme has been reviewed to ensure that it operates correctly, removing suppliers where a breach is known and monitoring any similar cases in the sector.
The Procurement team has also implemented a Supplier Code of Conduct that relates to supplier conduct and activity and specifically mentions modern slavery. This specifies that the University of Kent reserves the right to perform unannounced inspections and audits on or off the University campus or at supplier sites as necessary.
Four members of staff from different departments within the University attended a training event in September 2016 run by the British Universities Finance Directors Group. This was called “Managing Risks in the Supply Chain; your responsibilities under the Modern Slavery Act.”
A member of staff from the Procurement department attended "Advanced Modern Slavery training" run by the Ethical Trading Initiative in October 2017.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in the University’s supply chains and business, the University’s Procurement team intends to provide training to members of staff.
The University will take the following further steps to combat slavery and human trafficking:
- Roll out the Supplier Terms and Conditions documents, which include references to Modern Slavery, across the University;
- Review the supply chain and prioritise risks, considering specific categories and requirements that may have higher potential exposure to the requirements of the Act;
- Ensure that the practices of recruitment agencies are effectively checked before accepting workers from that agency;
- Instigate training and workshops for staff by Procurement to include the requirements around Modern Slavery;
- Periodically review the "compliance with the Modern Slavery Act" Risk on the University's Risk Register;
- Continually review the supplier vetting programme to ensure that it is operating correctly, remove suppliers where a breach is known and monitor any similar cases in the sector;
- Consider the wider implications of Modern Slavery and Human Trafficking, to include a review of other University activities, including investment and acceptance of gifts, as well as Procurement.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the University of Kent’s slavery and human trafficking statement for the financial year ending 31 July 2018.
This statement will be reviewed and updated on an annual basis.
Signed on behalf of the University of Kent
Sir David Warren
Chair of Council
Date: January 2019