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Modern Slavery Act 2015 (the ‘Act’)

Modern Slavery and Human Trafficking Statement - Financial Year 2020

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, 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 »Æ¹ÏÊÓƵ of »Æ¹ÏÊÓƵ does not engage with or condone the practices of human slavery, human trafficking or forced labour and is committed to improving its practices to combat slavery and human trafficking in its supply chains.

This Statement reflects the »Æ¹ÏÊÓƵ’s commitment to acting ethically and with integrity in all our business relationships and to implement and enforce effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in our supply chains.

This statement is made pursuant to Section 54(1) of the Act and constitutes our Groups Modern Slavery and Human Trafficking Statement for the Financial Year ending 31st July 2020.

The »Æ¹ÏÊÓƵ’s Organisation Structure

We are a provider of educational learning and research in the higher education sector.

The »Æ¹ÏÊÓƵ of »Æ¹ÏÊÓƵ has, within its group structure, seven subsidiary companies, only one of which is active. The »Æ¹ÏÊÓƵ has 1188 employees and operates in a number of countries.

Our supply chains

»Æ¹ÏÊÓƵ procurement follows one of two pathways:

(1) collaborative procurement (through HE Purchasing Consortia); or
(2) in-house tendering and contracting:

• The »Æ¹ÏÊÓƵ continues to be a member of the Southern Universities Purchasing Consortium (SUPC) which is, in turn, a member of Procurement England Limited (PEL). The »Æ¹ÏÊÓƵ by contracting within the SUPC framework agreements ensures compliance with sustainability policies and the Modern Slavery and Human Trafficking Statement 2015.
• The »Æ¹ÏÊÓƵ ensures that modern slavery is addressed on all new OJEU tenders with suppliers.

Our Policies

• The »Æ¹ÏÊÓƵ Policies demonstrates our commitment to act ethically and with integrity in all our business relationships, and implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
• Policies are being reviewed and the »Æ¹ÏÊÓƵ intends to take further steps to raise awareness of reporting procedures with all staff and students.

Due Diligence

Due diligence in relation to modern slavery and human trafficking embraces a range of actions which the »Æ¹ÏÊÓƵ undertakes to mitigate the risk of non-adherence to the Act:

• All staff to comply with this statement and current legislation in relation to their interactions with suppliers.
• All suppliers that contract with the »Æ¹ÏÊÓƵ must contract under the »Æ¹ÏÊÓƵ’s standard terms and conditions which have specific contractual terms relating to compliance with the Modern Slavery Act 2015.
• The use of consortia frameworks ensures that suppliers are properly vetted, and their working practices are regularly assessed for compliance with the Act.
• Due diligence completed during tender exercises is recorded on our e-tendering system.
• In the past year, no concerns have been raised by members of staff or external contractors regarding modern slavery within the »Æ¹ÏÊÓƵ’s supply chains. However, the »Æ¹ÏÊÓƵ continues to monitor compliance.

Plans for the future

Training

We intend to provide further specialist training for our staff to ensure a high level of understanding of the risks of modern slavery and human trafficking within our supply chains.

Other steps

Other steps we intend to take:

1. Develop a procurement action plan for combating modern slavery within our supply chains and monitor our effectiveness;
2. Continuing to identify, assess and monitor potential risk areas within our supply chains to mitigate the risk of slavery and human trafficking occurring;
3. Carry out further work to raise awareness amongst all staff through training and publication of information on internal websites;
4. Recording and monitoring any allegations or incidents relating to modern slavery reported to the »Æ¹ÏÊÓƵ by staff, suppliers and/or third parties.
5. Request that suppliers self-certify their compliance with the Act.

This statement has been approved and published by the »Æ¹ÏÊÓƵ’s Board of Governors and will be continued to be reviewed annually.

Chair of the Board of Governors of the »Æ¹ÏÊÓƵ of »Æ¹ÏÊÓƵ