Introduction

Modern slavery is both a criminal offense and a breach of fundamental human rights. It manifests in diverse ways, including slavery, servitude, forced labour, and human trafficking – all of which result in people being deprived of their freedom for personal or financial benefit.

UCA is committed to proactively preventing modern slavery in both our direct suppliers and in our supply chain as a whole. As a small organisation we also accept our ability to monitor our complex supply chains in foreign countries is limited, and therefore use external tools as necessary.

As an educational establishment dedicated to the creative arts, we are committed to embedding sustainable development into our academic provision. This includes encouraging students to consider concepts of global citizenship, issues of social justice, ethics and wellbeing. We do this by including the principle in our academic plan and adopting a truly international approach to recruiting and building the student community, almost one-fifth of our students come to study with us from overseas, travelling from many different nations. Students are encouraged to understand the consequences of actions which could impact on a community’s sustainable future. 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 the University’s slavery and human trafficking statement for the financial year ending 31 July 2024. It sets out the steps the University has taken to ensure that slavery and human trafficking do not take place in any part of our business or our supply chains.

UCA Organisational Structure

The University is a Higher Education corporation and an exempt charity under the terms of the Charities Act 2011. 

Our core business is the advancement of Higher Education and research in our specialist disciplines. Most of our income comes from tuition fees, we also receive some public funding directly from the Office for Students and Research England. We generate further income by providing accommodation and catering services to our students and staff. We have campuses across Surrey and Kent as well as centres in partner organisations. 

Due Diligence in our Business and Supply Chains

Our supply chain is diverse and includes multinational companies to sole traders. Goods and services are procured by all departments across the University. We continue to review our supply chain on an ongoing basis, both to ensure continuing best value and compliance with our policies, including the prevention of Modern Slavery.

We purchase goods or services from suppliers globally. Some of these countries are ranked as high-risk countries by the Walk Free Foundation’s Global Slavery Index 2018 and are of particular concern, although Modern Slavery can happen in any country.

We purchase many of our services through procurement frameworks, as part of these frameworks these suppliers will already have been vetted, however we will continue to ensure their compliance with our policies.

To raise awareness of modern slavery, new suppliers are required to provide signed confirmation of their undertaking to work alongside us in good practice and compliance with our policies. Additionally, every purchase order generated is accompanied by a link to the UCA terms and conditions outlining our policy.

All suppliers with which we spent over £25k were emailed in 2023 to remind them of our requirements along with a link to this statement.  In addition, we provided information on a confidential whistleblowing service they can use if they have any concerns about people at risk.

Risk Areas

Suppliers of goods / services which are at risk of being produced through a process using forced labour are prioritised for review on an ongoing basis. 
 
Goods that we procure that may be higher risk are:

  • IT / Electronic supplies
  • Furniture, furnishings, and textiles
  • Course materials
  • Food

Services that we procure that may be higher risk are:

  • Construction / maintenance
  • Security
  • Cleaning 

Relevant Policies

In keeping with our commitment to act with integrity in all our business dealings, many of our existing policies determine how the University conducts its business operations, to include sustainable, ethical, economic and social considerations in its purchase of goods and services and in the employment of staff.

Relevant Policies include:

Training

UCA is committed to provide targeted training in Modern Slavery and human trafficking, to aid compliance and heighten awareness. 

An online training module is compulsory for all new staff.   Going forward, in addition to being   compulsory for all new staff the module forms part of a refresher programme for staff. Staff are required to complete the current module on a biennial basis.

Progress since last statement

Since the last statement we have:

  • Continued the use of the Netpositive and Electronics Watch systems and incorporated them into the new supplier process.

Plans and commitment for the future

We are committed to continually developing and maintaining transparent working relationships with our suppliers and supply chains to ensure that there is no slavery or human trafficking in our supply chains.

Our plans for 2024/25 include:

  • UCA will be building on its position of positive notification. We will be increasing due diligence with regards to the crimes outlined in the Modern Slavery Act 2015. We will include scored qualitative questions into our tender processes for sectors that are identified as high risk, to include but not be limited to the Risk areas referenced within this document. This is particularly pertinent due to the number of service contracts we have requiring re-tending in the coming years that fall within at risk areas.
  • Purchase of an updated mandatory e-learning module with the ability to monitor usage.

This Statement has been approved and published by the University’s Board of Governors following a review in September 2024. In accordance with Section 54 of the Modern Slavery Act, 2015 this statement will continue to be reviewed at least annually.

Jeremy Sandelson
Chair of the Board of Governors University for the Creative Arts
10/07/24

Historical statements