Slavery and Human Trafficking Statement September 2020

Introduction

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 opposed to such abuses in our direct operations, our indirect operations and our supply chain as a whole. 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, drawing students from 55 countries in two hemispheres. Students are encouraged to understand the consequences of actions which could impact on a community’s sustainable future (UCA’s Strategy for Education for Sustainable Development). 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 2020. 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.

Organisational Structure

The University is an HE corporation and an exempt charity under the terms of the Charities Act 2011. Our core business is the advancement of Further and Higher Education and research in our specialist disciplines. The majority of our income comes from tuition fees and 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 are based on four campuses in the southeast of England with 6,120 enrolled students (2019/20) and 816 members of staff (at 31/07/20).

The University’s total income for financial year 2019/20 was £68.7m.

Our Supply Chains

The Supply Chain to UCA is varied and includes the supply of goods and services to support the effective running of the university. Key spend areas include: Estates/Facilities Management; information technology equipment and services; student materials and support; and public relations and   marketing. We also engage the construction industry for capital building projects. 

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:

  • Procurement Policy
  • Anti-Bribery, Anti-Corruption and Anti-Fraud Policy
  • Recruitment and Selection Framework
  • Disciplinary Policy & Procedure
  • Whistleblowing Policy
  • Modern Slavery

 

Training

Following a review in 2019, UCA committed as a matter of policy to provide targeted training in Modern Slavery legislation, avoidance and awareness. In furtherance of our commitment to ensure that all parts of our business and supply chain are slavery free we have implemented new training provisions for all staff.

An online training module was sourced and targeted training, promoted by the Vice Chancellor, was introduced for all staff during 2020. Going forward, the module is compulsory for all new staff as part of their induction training. 

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we have raised the profile of Modern Slavery within UCA and with our supply chain. We will continue to work with our HE colleagues and university consortia to identify best practice and work with them to understand and better manage key risk areas.

As part of this, processes, declarations and rigor are built into our tendering documents and systems to:

  • Identify and assess potential risk areas in our supply chains
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains
  • Monitor potential risk areas in our supply chains
  • Protect whistle blowers and report unethical conduct
  • Build relationships with recognised purchasing consortia which maintain suitable anti-slavery and human trafficking policies and processes

 

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and our contractors to comply with our values. Our invitation to tender document includes the statement that, in accordance with the Modern Slavery Act, UCA is committed to improving existing practices to combat slavery and human trafficking, by ensuring that slavery and human trafficking have no place in any part of our business or our supply chains. UCA has zero tolerance to slavery and human trafficking and we expect all those in our supply chain and our contractors to comply with the legislation. In turn, suppliers are required to confirm in writing that they conform to the requirements of the Act. 

Further to the above, the requirement for suppliers to conform to the act is strongly reinforced in our standard terms and conditions,

“You warrant and undertake that you are fully aware of the provisions of the Modern Slavery Act 2015 and that you have not and will not commit any act or omission which would place the University in breach of the Act, whether in connection with the contract or otherwise. You shall be liable for and will indemnify us against any expense, liability, loss, claim or proceedings whatsoever in respect of any breach by you of the provisions of this clause. In the event of any breach by You of the provisions of this clause, we shall be entitled by notice to you to terminate the Contract.”

Our plans 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. We will continue to monitor and work with suppliers to ensure ethical sourcing in all sectors; issuing annual reminders to all our suppliers as an affirmation of our annual statement and expectations. Should any supplier fall short in this respect we will work with that supplier to address any deficiency and ensure that high ethical standards are maintained.

This Statement has been approved and published by the University’s Board of Governors following a review in September 2020. In accordance with Section 54 of the Modern Slavery Act, 2015 this statement will continue to be reviewed at least once annually.

Jeremy Sandelson
Chair of the Board of Governors University for the Creative Arts
8 October 2020