Modern Slavery Act Statements in the University Sector – The Start of the Journey

26 April 2017      Emma Keenan, Procurement Specialist

Written by Dr Caroline Emberson, Enterprise Fellow, University of Nottingham Business School. As a practitioner, Dr Emberson worked within the clothing and textiles sector before moving into academia to research supply chain management. Her current interest is in the development of a supply chain risk impact assessment tool for modern slavery. Dr Emberson writes:

“With the introduction of the UK’s Modern Slavery Act (MSA), commercial organisations with a turnover of £36 million or more are required to produce an annual statement stating what steps they have taken to eradicate modern day slavery from their own organisation and from their supply chains. This includes commercial organisations in the public sector, such as UK Universities.

A review of the inaugural statements from 50 UK Universities, posted on the Business and Human Rights Resource Centre (BHRRC) website’s Central Registry for Modern Slavery Statements, reveals the steps Universities have taken to comply with this legislation.

In these early stages, only around a quarter of the Universities Statements reviewed clearly comply with the MSA’s signatory, approval and publication requirements. Like other commercial organisations, University statements must have the equivalent of Board-level approval, be signed by the equivalent of a Board Director and be posted via a link on the University’s home-page. The University sectors performance in this regard would seem to lag behind that of FTSE 100 companies, 56% of whom managed to comply.

It seems Universities have only just begun to take steps to better understand the human rights risks in their own organisations and in their supply chains. However, sector-specific consortia procurement initiatives, a risk-based approach to supply chain management, codes of conduct and the use of standardised procurement tools may all help the sector to make more speedy progress.

In the majority of statements Universities refer to their involvement in national, or one of the six regional, Higher Education purchasing consortia. These bodies are dedicated to improving both the quality and level of collaborative procurement across the Higher Education Sector. Procurement England Limited (PEL), the organisation to which these regional consortia belong, has developed its own ‘Sustainable Procurement Policy’. In a similar vein representatives from the London Universities Procurement Consortium (LUPC) and the Advanced Procurement for Universities and Colleges (APUC) are Trustees of ‘Electronics Watch’, an independent monitoring organisation working to achieve respect for labour rights in the global electronics industry through socially-responsible public purchasing, and of which a small number of Universities state that they are members. LUPC has also developed its own Slavery and Human Trafficking Statement, while the Higher Education Purchasing Consortium in Wales (HEPCW) works with suppliers it has designated high risk to encourage them to join the Ethical Trading Initiative and adhere to its Base Code.

Slightly under half of the Universities state that they have already conducted initial risk assessments and have identified one or more procurement categories or internal operations as being of particular risk. Unfortunately, for the purposes of comparison, these categories are given at different aggregation levels making direct comparison difficult. For example, while some Universities state ‘Estate goods and services’ are an area of high risk, others break it down into ‘Facilities Management’ or separate categories of ‘Cleaning’, ‘Security’ and ‘Catering’. With this caveat, a Top 10 category ranking identifies as the purchase of ICT equipment as the sector most frequently rated as high risk.

Top 10 high risk categories ranked by frequency

Rank      Category

1           IT/IST/ICT Equipment (21)

2           Estate Goods and Services (15)

3           Construction (12)

4           Cleaning (12)

5           Office supplies (11)

6           Security services (11)

7           Laboratory consumables (11) (including lab goods)

8           Catering/ food supply chain (10)

9           Clothing (8) (including healthcare & reception uniforms, sports clothing and gowning)

10          Facilities management (7) (including maintenance)

Nearly a third of Universities state that they used a code of conduct with at least some of their suppliers. Of these codes, the most popular seem to be the APUC’s Code of Conduct and the Ethical Trading Initiative’s Base Code.

A similar number of Universities also describe the adoption of a variety of procurement tools. The most popular of these is NetPositive Supplier Engagement Tool, developed by the North West Universities Procurement Consortium (NWUPC), The Universities Catering Organisation (TUCO), the North East Universities Procurement Consortium (NEUPC) and the Southern Universities Procurement Consortium (SUPC). Next in the popularity stakes are the DEFRA Sustainability Procurement Prioritisation tool (SPPPT) and the APUC’s ‘Sustain’ Tool.

A few Universities state that they have set up dedicated, multi-functional compliance teams and one University, SOAS, describes changes it has made to its facilities management service contracting where a consolidation of a number of smaller contracts reduces the modern slavery risk of dealing with a large number of smaller organisations. However some of the steps advocated by other universities may not have such beneficial outcomes. Somewhat against conventional wisdom, a number of Universities explain that a zero-tolerance stance on modern slavery means that they are prepared to sever contractual ties with any organisation convicted of modern slavery practice. Civil Society Organisations and other experts in the field suggest that, rather than expulsion, a more effective approach is to work with stakeholders to eradicate slavery from the communities of which it is a part. The journey continues.”

There are various ways those responsible for the Modern Slavery Act statement can increase their knowledge in this area. HEPA are working with the Ethical Trading Initiative (who also provide training via CIPS in this area) to run a one day training course, covering all you need to know, and will run in different locations around the country where demand permits. If you would like to hear more about this please express your interest to Emma Keenan. Additionally, the University of Nottingham are running a Free Massive Open Online Course (MOOC) starting on 8th May entitled, “Ending Slavery”.  It is a 4-week course, and you can find out more information or register here

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