Modern Slavery Statement
Slavery and Human Trafficking
We're committed to combating slavery and human trafficking in our supply chains and in January 2017, we made our first annual statement under the Modern Slavery Act 2015.
The statement below sets out the steps that we plan to take in the next 12 months to ensure that, as far as possible, slavery and human trafficking are not taking place in any part of our organisation.
Our Slavery and Human Trafficking Statement
The University of Portsmouth is committed to combating slavery and human trafficking in its supply chains. The University made its first annual statement under the Modern Slavery Act 2015 in January 2017. This statement provides an update on the actions proposed in its first annual statement and sets out the steps that the University plans to take over the coming 12 months to ensure that, as far as possible, slavery and human trafficking are not taking place in any part of our organisation.
The University's structure
The core business of the University of Portsmouth is teaching, research and innovation, undertaken by five academic faculties supported by professional services. The University has approximately 23,000 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.
Procurement in the University of Portsmouth
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 chains.
The University's supplier base 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)
Update on Activities
In the 2017 Modern Slavery Statement the University said it would aim to deliver the following:
- 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.
- 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.
- Establish the checks, assurances and investigations we can reasonably conduct.
- 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.
- Conduct a risk assessment to determine where risk may lie within the University's supply chain (Aim in 2017: Top 25 Suppliers).
- 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).
- 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.
- 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.
- 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.
- 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.
- Find out what training exists in this area and what training needs to be developed going forward for appropriate staff within the University.
Over the last year the University has taken a number of steps to gain a better understanding of what the risks of modern slavery are within its supply chain and to put in place processes and procedures to address these risks.
A Modern Slavery Act lead has been nominated within the Procurement team who is responsible for coordinating and recording all activity in this area.
We have gathered information on our top suppliers in relation to their summary statements of how they will prevent slavery and trafficking. We have also drafted questionnaires to be sent to our top 25 suppliers to gain a more detailed insight into their supply chains and to gain assurances around their existing processes for combatting modern slavery.
The University now uses a pre-qualification questionnaire which includes a series of questions in relation to supplier compliance with the Modern Slavery Act and is working through its suite of procurement contracts to ensure that all include appropriate clauses on modern slavery.
Appropriate training has been sourced for the Procurement team on the implications of the Modern Slavery Act and guidance on the actions they can take on a day to day basis to detect and flag risks in this area. The whole Procurement team will undertake this training before the end of 2017.
We are working towards the objectives we set in our first annual modern slavery statement and good progress has been made on key activities. Moving into our second year of compliance with the Modern Slavery Act, we now have a much better understanding of the activities that are important for the University and have set our specific objectives for the next 12 months accordingly.
Activities for the Next 12 months
As a result of the activities undertaken above, the University has now gathered more information about its suppliers and their supply chains. Over the next 12 months the University will:
- Analyse the information we receive to conduct a more thorough assessment of where the key areas of risk lie for the University and produce a plan of the further work is required, including further supplier engagement and audits where required.
- Work with suppliers who do not have acceptable policies and procedures in place to address the risks of modern slavery. Where necessary, the University will terminate contracts with suppliers who do not meet the University's ethical standards in this area.
- Develop and implement an Anti-Slavery & Human Trafficking Policy.
- Undertake an exercise to 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.
Chair, Board of Governors
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 2017.