Modern slavery and human trafficking statement 2021-22
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 2022.
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 19,400 students and over 3,500 staff. In 2021/22, we had total income of £337.3 million and total expenditure of £388.4 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 employer 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: the Provost and Deputy Vice Chancellor, three Pro Vice Chancellors, the Chief Operating Officer, the Chief Financial Officer, nine School Deans, the Deputy Chief Operating Officer and Director of Student Services, 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 2021-22 spend profile, where total procurement spend was £70m)
|University area||Indicative percentage split|
|Estates / Construction||42.5%|
|IT & Telecommunications||10.7%|
|Laboratory & Medical||8.5%|
|Travel & Accommodation||4.8%|
|Domestic / Cleaning||1.2%|
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, 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. 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. 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, meaning 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 to mitigate the risk of modern slavery within their supply chain. The tool allows the University to run reports to see supplier progress against identified actions within their plan(s). The University’s template contract award letter encourages suppliers to use the tool, where its use is not to be made contractual due to the significance of slavery (or sustainability factors) given the nature of the contract. Furthermore, our contract summary template, which is completed by the Procurement Team 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, as well as our contract review meeting agenda template, also note 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 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 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). Staff have also been made aware of the series of Modern Slavery webinars provided by The UK Universities Purchasing Consortium (UKUPC) covering the Modern Slavery Act and key warnings of Modern Slavery.
Our effectiveness in combating slavery and human trafficking
All tendering exercises undertaken by the Procurement team during 2021/22 incorporated the standard modern slavery risk mitigation measures built into our procurement process. The procurement team also now has a dedicated resource to contract management to ensure a continued dialogue with suppliers to the University.
The NEUPC have recently established an affiliate membership with Electronics Watch on behalf of its members. Electronics Watch is an independent monitoring organisation established with the purpose of protecting the rights of workers within supply chains. Their particular focus is on electronic purchasing in the public sector. The Head of Commercial Finance, along with other University staff, have confirmed their membership to Electronic Watch through this affiliation, have signed up to receive monthly updates and continue to work towards being fully active affiliates through, among other things, communicating to colleagues the importance of socially responsible procurement.
The Procurement team 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.
We have also made use of the resources developed as part of Stronger Together’s Construction Programme, adding the following requirement to our Invitation to Tender template for Estates/Construction category contracts
To mitigate the risk of modern slavery within its supply chain, the Contractor must:
- Ensure that the Site Manager (as a minimum) has undertaken training on how to identify and respond to signs of modern slavery among Contractor employees working on the University site; and
- Clearly display posters about the University site explaining, in all relevant languages, what forced labour is and how to report incidents of it, including via the Modern Slavery Helpline.
StrongerTogether also provides resources for fulfilling such requirements.
Chief Operating Officer
On behalf of the Council of Loughborough University which approved this statement on 23 November 2022.