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Modern Day Slavery Statement Update 2016-17
Introduction
The purpose of this document is to provide an update on UCL's commitment to ensure our supply chains are free of Slavery and Human Trafficking.
In our Slavery and Human Trafficking Statement we committed to the following initial actions:
- Implementation and enforcement of effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chains.
- Commitment to better understand our supply chains and working towards greater transparency and responsibility towards people working in them.
- Monitor supply chains that have been identified as a potential risk and take appropriate action as necessary.
Our initial statement identified a number of purchasing categories that were high risk in terms of the potential for slavery, servitude, forced and compulsory labour, and human trafficking, referred to as Modern Slavery in this statement. These were:
- Office supplies,
- Laboratory consumables,
- Computing- ICT and AV equipment,
- Some estates services, such as cleaning, catering and security services
What have we done?
Procurement process
We have embedded our commitment to compliance with the Modern Slavery Act within our Sustainable Procurement Strategy. This strategy supports all procurement processes, thereby allowing the implementation and enforcement of effective systems and controls.
UCL is a Member Institution of the Southern Universities Purchasing Consortium (SUPC); when using SUPC frameworks, Modern Day Slavery compliance issues are covered by the Purchasing Consortium. For example, UCL's IT equipment is predominantly procured through SUPC, who are members of the Electronics Watch, an organisation that protects labour rights for workers of electronic manufacturers.
We already disqualify any prospective supplier if in the last 5 years they have been convicted of child labour and other forms of human trafficking. Additionally, we have embedded Modern Slavery Act considerations into the Selection questionnaire documents in our procurement processes. This enables better control to ensure Modern Slavery is not in our supply chains. Specifically we ask:
- "Are you a relevant commercial organisation as defined by section 54 ("Transparency in supply chains etc.") of the Modern Slavery Act 2015 ("the Act")?
- Are you compliant with the annual reporting requirements contained within Section 54 of the Act 2015?
Staff Development
We have ensured all Procurement Officers involved in purchasing from high risk categories have received advanced training on identifying and assessing Modern Day Slavery risks within the supply chain, though the use of an impact analysis exercise.
Procurement staff attended a Modern Day Slavery workshop to understand this area further.
Monitoring our supply chains
We have additionally identified travel, agriculture and furniture spend categories to be high risk, through the Defra prioritisation exercise. Going forward these will be added to our high risk list, as a priority for investigation and engagement.
Supplier engagement and development
Through utilising the NETpositive tool, we are committed to better understand our supply chains, and enable greater transparency and responsibility towards people working in them. The tool has only recently been launched. However, we have already asked all suppliers that have stated they supply UCL whether they are aware of the Modern Slavery Act. For those that stated "no" we have contacted them to explain Modern Day Slavery and link to The Governments webpage on Modern Day Slavery.
What do we plan to do over the coming year?
Procurement process
We will fully embed Modern Slavery Act considerations into our procurement process from the Selection Questionnaire through to contract management, and enable staff to develop their understanding of Modern Slavery.
Tender questions for suppliers (both at SQ and ITT stage) will be reviewed to ensure they are relevant and encourage increased investigation into Modern Day Slavery.
Impact analysis will be embedded within our contract tender process, which will enable Modern Day Slavery to be considered by procurement professionals from the start of the tender process. This will help deliver effective systems and controls on Modern Day Slavery.
Staff Development
We will identify training opportunities to further skill procurement staff in addressing and investigating Modern day Slavery
Monitoring our supply chains
Having identified high risk categories, we will monitor these through the NETpositive tool. This will help to drive our strategies to monitor suppliers to UCL in these categories.
Supplier engagement and development
The NETpositive tool will be used to manage suppliers and encourage improvement in addressing Modern Day Slavery through our supply chains.
We will contact our top 1,000 direct suppliers (based on total spend and number of purchases), as well as suppliers of high risk categories, and ask them to sign up to the NETpositive tool. This will enable UCL to understand:
- Which of our suppliers are aware of the Modern Day Slavery Act
- Which of our suppliers consider Modern Slavery to be an issue for their business
- Which of our suppliers are taking pro-active action with regards to the Modern Slavery Act and the progress they are making.
This approach and the evidence gathered, will assist us in understanding our supply chains and working towards greater transparency and responsibility towards people working in them. We will target our activities to those suppliers and supply chains who are either not aware that Modern Slavery is an issue for their business or are not taking a pro-active approach within their supply chains.
Rex Knight
Vice Provost, Operations
October 2017