Slavery and Human Trafficking Statement
This statement sets out the steps that the University of Portsmouth plans to take over the coming twelve months to ensure as far as possible that slavery and human trafficking are not taking place in our supply chains or in any part of our business. It has been developed to ensure the University meets its obligations under the Modern Slavery Act 2015.
Our organisation’s structure
The core business the University of Portsmouth is teaching, research and innovation, undertaken by five academic faculties supported by professional services. The University has approximately 22,000 students and 2,500 staff. The university is supported by a centralised procurement and contracting function located within the Finance Department with transactional purchasing devolved to individual faculties and services.
The Procurement function
The University of Portsmouth’s Procurement Team currently manages a spend of approximately £70million per annum. The diverse nature of the spend, involves dealing with a large number of suppliers, their sub-contractors and their supply chain. Due to this large and diverse supply base the risks of trading in an unethical way, are potentially quite high. As such, actions have been taken to mitigate against these risks.
The University is committed to acquiring goods and services without causing harm to others.
The main objective of this statement is to inform all key stakeholders of the University of Portsmouth of its positon and policy in respect to modern slavery, human trafficking, forced and bonded labour and labour rights violations in its supply chains. The statement seeks to detail the risks inherent in its supply chain and the steps we are taking to address them.
The University’s aim is to adopt a zero tolerance approach to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we are now introducing a range of compliance checks. These are detailed in this policy.
The University’s Spend Categories
The University has a very diverse spend profile. This ranges from cutting edge scientific/engineering equipment to everyday stationery and furniture. The spend breaks down into the following categories:
- Audio Visuals
- Cleaning and FM Services
- Communications and Marketing
- Computing – ICT Equipment and Services
- Food and Beverage
- Office Supplies (Stationery)
Our initial aim over the next 12 months will be to examine these key category areas and highlight which ones pose the biggest risk to the University in terms of meeting its aspirations on Slavery and Human Trafficking. The results of this initial analysis will lead to a number of initiatives commencing during 2017. We anticipate possible Initiatives should include those shown in the attached action plan. A brief explanation of these activities is detailed below.
Activities for the Next 12 months
As part of its commitment to the above policy the University aims to deliver the following initiatives:
1) Allocate a Modern Slavery Act Lead in the Procurement Team. The role of this person will be to keep a record of all relevant procurement initiatives and activities.
2) Communicate our expectation to key partner organisations and key suppliers that they should have developed their own summary statements of how they will prevent slavery and trafficking
3) Establish the checks, assurances and investigations we can reasonably conduct.
4) Establish how we will factor legal and fair labour costs into sourcing costs to ensure we avoid the suppliers that use slave and bonded labour.
5) Conduct a risk assessment to determine where risk may lie within the University’s supply chain (Aim in 2017: Top 25 Suppliers).
6) Mitigate the risk of slavery and human trafficking occurring in our supply chains and the wider business by working with the suppliers of our large contracts to gain a detailed insight into their supply chains (Aim in 2016/2017 – Top 25 Suppliers).
7) Engage with suppliers to obtain assurances we need. This will consist of specific questionnaires for existing suppliers to complete in order to satisfy us that issues are being addressed (Aim 2017 – Top 25 Suppliers). This may take time to achieve if we are already in contract.
8) Develop questions for Pre-Qualification questionnaires. Suppliers will have to self-certify that they comply with this initiative. Answers that subsequently prove to be incorrect may result in cancellation clauses in contracts being invoked.
9) Work with the University’s legal advisors to develop a statement in ITT documentation which forms part of the Form of Offer in our tender process.
10) Work with the University’s legal advisors to develop clauses within our contracts with overseas partner institutions and recruitment agents to ensure that they do not engage in activities that support slavery or human trafficking.
11) Find out what training exists in this area and what training needs to be developed going forward for appropriate staff within the University.
As part of this reporting exercise in this and the coming years, the University of Portsmouth confirms its commitment to better understand its supply chains and to work towards greater transparency and responsibility towards the people working in them.
Chair, Board of Governors