Modern Slavery Statement
Structure and governance
Slavery and Human Trafficking StatementThis is the fourth statement that the University of Portsmouth ("the University") has made pursuant to the requirements of the Modern Slavery Act 2015. The University remains committed to tackling human trafficking in its supply chains and in all other areas of our activity. In this statement we will provide an update on the actions we committed to achieve in our previous annual statement and, reflecting on our previous activity in this area, we will set out the progress that the University plans to take over the coming twelve months to ensure, as far as possible, that slavery and human trafficking are not taking place in any part of our organisation or its supply chains.
The University's Structure
The core business of the University is teaching, research and innovation, undertaken by five academic faculties supported by professional services. The University has approximately 24,000 students and 2,600 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
As a public body the University complies with the Public Contracts Regulations 2015, and currently manages a spend of approximately £115 million per annum. The diverse nature of the requirements 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 and materials required for the delivery of core business to the goods and services necessary in the operation of a successful University. Modern slavery is considered as part of each category or project strategy in terms of likelihood, and any relevant mitigating actions required for its identification are identified.
Update on Activities
In our previous Modern Slavery Statement the University said it would aim to achieve the following:
- Follow up with suppliers who have not responded to the University's modern slavery questionnaire.
- Issue a further 20 supplier questionnaires which capture significant new suppliers (by volume of trade) engaged since the last modern slavery statement was published.
- Conduct full analysis of the returned questionnaire and identify any themes or key risk areas.
- Develop a University modern slavery audit template document and carry out at least one pilot physical supplier audit, with modern slavery and human trafficking as its central theme.
During the year we have issued further modern slavery questionnaires to an additional 20 suppliers. Drawing together the information we have gleaned from supplier engagement to date, a number of key themes have emerged:
- Suppliers targeted can generally show good compliance with requirements from the perspective of procedures that they have in place with their direct suppliers. This is not surprising as most are large organisations with an awareness of their compliance requirements. However, most are weaker when questioned about knowledge and practices further down their supply chains which, in reality, is where the highest level of slavery is likely to occur.
- Most organisations surveyed had in places policies and processes for dealing with slavery in their organisation. Many had staff training programmes and sanctions against staff for breach of agreed procedures.
- Few organisations conducted supplier audits or had any third party involvement in assessing
the level of risk throughout their supply chain.
- We have to date approached suppliers on the basis of their total spend with the University. Having reviewed responses, we feel that engagement would be more meaningful if we were to target those suppliers who operate, or whose supply chain operate, in sectors which are found to be at high risk of slavery and human trafficking.
A modern slavery audit template was developed for use in supplier audits. This was trialled in a supplier audit. The audit was intentionally carried out without notice to allow us to assess the supplier's processes and procedures on modern slavery without them being able to prepare documentation in advance. The result was the provision by the supplier of little meaningful information. If we are to deploy supplier audits in future we will consider whether advance notice is more appropriate, and look again at the questionnaire content to ensure that we ask more probing questions, and couch them in more engaging language if we are to elicit useful data. We also plan to look at how we can more effectively enforce contractual sanctions against suppliers who have deficiencies in their modern slavery processes.
Activities for the next 12 months
For the past three years since the introduction of the mandatory modern slavery statement, the University's action plans has been very much focussed on gathering data and analysing supplier practices. Moving forward, we would like to use this information to take a broader, pro-active approach to tackling modern slavery, drawing on best practice and guidance from organisations such as the Business, Human Rights and the Environment Research Group. With this in mind, the University's targets for the next 12 months are as set out below:
- Use communication strategies to increase awareness generally within the University of the risks and implications of modern slavery and the steps that staff can take to work with the University to tackle this issue.
- Trial the Higher Education Procurement Association's online modern slavery training programme with targeted employees and report in the next annual statement on the numbers of employees trained and in which areas.
- Include coverage, where appropriate, of modern slavery within the University's Procurement Strategy document.
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 2019.