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¶¹ÄÌÊÓƵ University Modern Slavery and Human Trafficking Statement 2024

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act) and constitutes ¶¹ÄÌÊÓƵ University’s (¶¹ÄÌÊÓƵ) modern slavery and human trafficking statement for the financial year ending 31st July 2024. This is ¶¹ÄÌÊÓƵ’s ninth statement and previous statements remain available .

¶¹ÄÌÊÓƵ’s organisational structure

¶¹ÄÌÊÓƵ is a higher education provider created by statute and is an exempt charity. ¶¹ÄÌÊÓƵ is responsible to the Office for Students (OfS) as principal regulator for Higher Education Institutions in ¶¹ÄÌÊÓƵ that are exempt charities. The ¶¹ÄÌÊÓƵ Board oversees the strategic development of ¶¹ÄÌÊÓƵ and ensures the effective use of resources and the solvency of the institution. Its members are also ¶¹ÄÌÊÓƵ’s charitable trustees. Further details about ¶¹ÄÌÊÓƵ’s structure and governance can be found on the ¶¹ÄÌÊÓƵ website .

¶¹ÄÌÊÓƵ has undergraduate and postgraduate students who are attracted to ¶¹ÄÌÊÓƵ from all over the world. ¶¹ÄÌÊÓƵ is organised into several Faculties comprising; the Faculty of Health and Social Sciences, Faculty of Media and Communication, Faculty of Science and Technology, the ¶¹ÄÌÊÓƵ University Business School and also the ¶¹ÄÌÊÓƵ Doctoral College. ¶¹ÄÌÊÓƵ also has several professional service departments which include, amongst others; Finance, Academic Services, Estates, Marketing and Communications, Human Resources and Organisational Development, Student Services and IT Services.

¶¹ÄÌÊÓƵ has three wholly owned subsidiary companies; ¶¹ÄÌÊÓƵ Innovations Limited, The ¶¹ÄÌÊÓƵ University Foundation and ¶¹ÄÌÊÓƵ Community Business Limited. ¶¹ÄÌÊÓƵ also undertakes collaborative work and enters into academic partnerships with other research organisations and businesses around the world.

¶¹ÄÌÊÓƵ’s student and staff activities

¶¹ÄÌÊÓƵ continues to have a staff member who chairs the CPS Wessex Modern Slavery Scrutiny Panel which reviews human trafficking and modern slavery cases across the region.

¶¹ÄÌÊÓƵ also has a staff member who has worked in partnership with the National Police Chiefs’ Council to lead a roundtable event in London to identify critical gaps in addressing modern slavery and human trafficking and has also established a Modern Slavery Research Network which has national and international expert members who share insights and discuss ongoing work in this area.

Our academics and some post-graduate students are currently conducting research projects for or with anti-human trafficking organisations and police forces and are building relationships with other universities both nationally and internationally renowned for their research and publications on modern slavery and human trafficking.

¶¹ÄÌÊÓƵ also raises awareness as part of the curriculum for students in relevant subjects including Criminology and by inviting external speakers.

¶¹ÄÌÊÓƵ supply chains and supplier adherence to ¶¹ÄÌÊÓƵ’s values

¶¹ÄÌÊÓƵ’s supply chains for goods and services are complex and multi-tiered, and span from individuals to national and international entities. ¶¹ÄÌÊÓƵ conducts annual diligence assessments with contracted suppliers to confirm their compliance with the Act. The due diligence process maintains focus on high-risk sectors within supply chains, which include; security services, construction/estates goods and services, catering/food supply chains, cleaning/domestic services, waste, ICT equipment/general electronics and clothing/textiles.

¶¹ÄÌÊÓƵ continues to seek assurances from suppliers and contractors of their compliance with the Act via our tender procedures (utilising Government’s standard Selection Questionnaire for all above threshold procurements), by contacting key suppliers in the higher risk areas, reviewing contracts with suppliers considering the need to prevent modern slavery and having Modern Slavery Act 2015 clauses in our ¶¹ÄÌÊÓƵ standard terms of business for procurement and other supplier contracts.

¶¹ÄÌÊÓƵ policies and due diligence processes

¶¹ÄÌÊÓƵ implemented Anti-Slavery and Human Trafficking Policy and Procedures in 2016 which provide a reporting mechanism for all staff to raise concerns. The Policy and Procedures are formally reviewed and approved at least every two years and were most recently considered by the Audit, Risk and Governance Committee on behalf of the Board in November 2023. The Audit, Risk and Governance Committee has a standing agenda item to receive reports of any concerns raised under the Policy and Procedures and has oversight, along with the ¶¹ÄÌÊÓƵ Board, of compliance with the Policy and Procedures. During the 2023/24 financial year no reports were received and no welfare reports from students regarding modern slavery concerns were received during the reporting period. The ¶¹ÄÌÊÓƵ Whistleblowing (Disclosure in the Public Interest) Policy also protects staff, students and anyone working for ¶¹ÄÌÊÓƵ (including casual workers, self-employed contractors, agency personnel) and allows them to raise concerns related to modern slavery or risk of modern slavery.

¶¹ÄÌÊÓƵ continues to mitigate the risk of modern slavery and human trafficking within its own staff community by following fair HR recruitment and selection processes and applying its Recruitment and Selection Procedures which are reviewed and approved by the Director of Human Resources. Training is provided for staff involved in recruitment and staff cannot chair a recruitment and selection panel unless they have completed that training. All pre-employment checks are completed centrally by the Human Resources team to ensure compliance. Where recruitment agencies are used, ¶¹ÄÌÊÓƵ requires that such agencies comply with all UK legislation relating to the employment rights and welfare of candidates. ¶¹ÄÌÊÓƵ also ensures that staff and students are able to access grievance procedures and raise concerns whether working remotely or on campus.

¶¹ÄÌÊÓƵ has a number of frameworks which underpin its ethical standards across all of its business activities including the Research Ethics Code of Practice: Policy and Procedure, the Due Diligence Framework for research partners, the Partnership Approval Policy and Procedure, the Sponsorship Policy and Procedure and the Code of Ethical Fundraising and Donors’ Charter. ¶¹ÄÌÊÓƵ has also remained committed to playing its part in delivering the UN Sustainable Development Goals and worked to further embed the UN SDGs into all areas of ¶¹ÄÌÊÓƵ. ¶¹ÄÌÊÓƵ also continued to apply the following policies to ensure the procurement of goods and services took account of their social impact and to achieve ethical standards of business conduct; Sustainable Procurement Policy, Sustainable and Ethical Food Policy, Fair Trade Policy, Sustainability Policy, Sustainable IT Policy and Sustainable Construction Policy. ¶¹ÄÌÊÓƵ also has an Ethical Investment Policy in which slavery and child labour are identified as areas in which investment is deemed inappropriate.

To ensure that ¶¹ÄÌÊÓƵ takes full account of the economic, social and environmental implications of the goods, works and services it buys from external suppliers and organisations, ¶¹ÄÌÊÓƵ utilises a suite of sustainability questions created by the Sustainability team which colleagues in Procurement and the Stakeholder select from when finalising the invitation to tender questions. Mandatory questions around compliance with the Act are included within the standard Central Government Selection Questionnaire for all above threshold procurements and similar questions are also included within ¶¹ÄÌÊÓƵ’s Public Contract Regulations threshold templates.

¶¹ÄÌÊÓƵ also continued to procure goods and services via consortium frameworks such as the Crown Commercial Service (CCS) and through its membership of the Southern Universities Procurement Consortium (SUPC) which is a membership-based buying organisation for universities and further education colleges.

Training and Raising Awareness

¶¹ÄÌÊÓƵ has dedicated representatives who are aware of the requirements of the Act from Legal Services and Corporate Governance, Human Resources, Procurement and Sustainability and who are working to increase knowledge and skills around identifying, addressing and preventing modern slavery risks. Oversight of slave labour matters is carried out by UET and the Sustainability Committee to ensure executive scrutiny .

¶¹ÄÌÊÓƵ remains committed to working with local charities and organisations to raise awareness in the community. and as part of internal and external training sessions, ¶¹ÄÌÊÓƵ ensures that relevant staff members are made aware
of the risks of modern slavery and human trafficking in ¶¹ÄÌÊÓƵ’s supply chains and its business.

¶¹ÄÌÊÓƵ’s effectiveness in combating slavery and human trafficking

¶¹ÄÌÊÓƵ will continue to review the effectiveness of its measures taken to combat slavery and human trafficking on a periodic basis and will review its approach against the new legislative measures expected from the Government following the transparency in supply chains consultation.

¶¹ÄÌÊÓƵ will monitor how the challenges of inflation impact on our ability to identify and address risks of modern slavery in our operations and supply chains through contract review meetings and in new procurements. ¶¹ÄÌÊÓƵ will take such action as deemed necessary to maintain the highest levels of ethical and human rights principles in its business conduct and will monitor any emerging or heightened risks during the 2024/25 financial year.

Approval

This statement has been approved by the ¶¹ÄÌÊÓƵ Board who, together with the Audit, Risk and Governance (ARG) Committee, will review and update it as necessary on an annual basis.

Approved by the ¶¹ÄÌÊÓƵ University Board on 29th November 2024 Signed by Professor Alison Honour, Vice-Chancellor and Chief Executive Officer and University Board Member