Commercial and Procurement Services


Modern Day Slavery Statement Update 2018-19

This statement is to give an update on the work UCL has undertaken in the past year, to value the people working at UCL and within our supply chains, and to protect them from slavery and exploitation.


During this year the University has developed a new Sustainability Strategy, which has provided an opportunity to review our work to date on modern slavery and set objectives to drive further impact. The strategy includes commitments to address Modern Slavery, specifically to conduct Modern Day Slavery audits of our supply chain.  

In addition, we continually review our employment practices, and ensure that we are compliant with employment legislation, best practice, and ACAS codes of conduct. We engage and consult with our staff and our recognised trade unions on their terms and conditions, and employment practices.   

For example, we have worked with UNISON on harmonising the terms and conditions of Sodexo, Aramark and Axis to ensure that their staff, who work solely for UCL, enjoy the same terms and conditions as UCL staff.   

We also pay the London Living Wage, and we are working towards the Mayor of London’s Good Work Standard award. 

We have taken further steps to protect people, having developed action plans for the highest risk categories for exploitation. This includes assessment of high risk products, monitoring approved contracted suppliers, and road-mapping where contract terms could be improved. We will implement these and report progress next year. 

We have continued to engage our supply chain to ensure our suppliers are signed up to the supplier engagement tool, NETpositive, which allows UCL to offer free bespoke sustainability action plans to our suppliers.

UCL’s Procurement department are requiring this as part of new contracts, and communication has been sent out to our approved contracted suppliers. This has resulted in over 1,200 suppliers signed up to the tool, 400 more than last year. This is providing more data for us to analyse. We now know which of our approved contracted suppliers are still not on the tool and will target these to sign up.  

We will also engage those suppliers who are demonstrating best practice, to share and gain knowledge across our diverse spend categories.  


The purpose of this document is to provide an update on UCL's commitment to understand our supply chains and identify, prevent and mitigate Modern Day Slavery across them.  

In 2016, UCL published its first Modern Day Slavery Statement, followed by annual updates. This is our update for the financial year ending 31st July 2019. This work has primarily been led by Procurement Services and Sustainability. 

In our inaugural Slavery and Human Trafficking Statement we committed to the following initial actions: 

  • Implementation and enforcement of effective systems and controls to tackle slavery and human trafficking which may be taking place in our supply chains. 
  • Commitment to better understand our supply chains and work 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. 

About us

UCL is London's leading multidisciplinary university, with more than 13,000 staff and 42,000 students from over 150 different countries.  

Founded in 1826 in the heart of London, UCL was the first university in England to welcome students of any religion and the first to welcome women on equal terms with men.  

UCL is comprised of 11 Faculties.  

UCL is an exempt charity, in accordance with the Charities Act 2006 and receives funding from multiple sources to support activities and research. 


UCL's main campus is in the heart of Bloomsbury, London, however we have buildings across the UK.

UCL is building a new campus at Queen Elizabeth Olympic Park, to form part of a wider education and cultural quarter in the capital.

UCL also work with partners all over the world.

Supply Chains

UCL procurement activities amount to £600M+ annual spend, procuring a wide range of goods and services to support the effective running of the university, across diverse supply chains, including:

  • construction and estates,
  • furniture,
  • stationery,
  • electronics (computers, audio visual etc.),
  • travel services,
  • books and printing,
  • laboratories and medical,
  • security services,
  • waste and recycling services.

The goods and services are procured from suppliers across the world and our direct suppliers range from local SMEs though to large multi-national/global companies. Much of our expenditure is made through consortia framework agreements. 
UCL employs spend orientated procurement managers for key categories, who specialise in understanding the supply chains of these sectors. We conduct risk analysis to understand likelihood of exploitation in different categories, and prioritise action according to this risk. 

  • electronics (computers, audio visual etc.),  
  • travel services,  
  • books and printing,  
  • laboratories and medical,  
  • security services,  
  • waste and recycling services.
Forced Labour and Human Trafficking High-Risk Area

Diverse and global, many (if not all) of our supply chains are at risk of exploitation and Modern Slavery. However, through developing our understanding of the issue, we have identified a number of particularly high-risk areas to UCL:

  • We purchase electronic equipment, including IT hardware and AV equipment, with parts (including minerals) sourced globally and predominantly manufactured in Asia. 
  • Within catering, we purchase fish, meat and vegetables from the UK, a sector high for reports of UK labour exploitation. We also source products that contain palm oil, cocoa and sugar cane, which are all high-risk products. 
  • UCL is undertaking a large construction programme, with many contractors and subcontractors working on UCL construction sites. In the construction industry there is a risk of forced labour being used.
  • Our main Facilities Maintenance contracts, including catering, cleaning and waste collections are outsourced to third party companies, who rely on a mix of UK and foreign staff. There has been a rise in reports of Modern Slavery in waste and recycling centres nationally.


Managing the risk of Modern Day Slavery

UCL takes a holistic approach to managing the risk of exploitation and slavery.

We have policies, strategies and procurement processes to assess suppliers and purchasing decision, while we have risk assessment exercises and actions plans to ascertain where we should focus our resources on high risk areas, in order to have the greatest impact.

Policies and Governance

A number of existing policies can be considered to support fair working practices for our staff and suppliers, and ensure we buy ethically:

Sustainability Strategy

In 2018/19 we conducted a consultation for the University’s new sustainability strategy, which was approved by UCL Council in July 2019. The strategy challenges UCL to procure and buy products and services which are good for people and the planet. Our strategy commitments include:  

In 2020 we will:  

  • Train purchasing staff in sustainable and ethical procurement best practice. 

In 2021 we will: 

  • Conduct a Responsible Procurement Code Audit 
  • Undertake Modern Slavery audits of major suppliers in high risk categories. E.g. food, electronics and construction. 
  • Work with our suppliers with the aim of introducing sustainability ratings for products on the e-marketplace and canteens.
Procurement Process

Standard questions for tender

Our last update stated we had written additional standard questions for our tender process, utilising best practice (Government’s Transparency in Supply Chains Guidance and the Ethical Trading Initiative’s Guidance).

These revised standard questions for our tender process have been used in our catering, printing services and managed print contract tenders.  

We want to include these into stock tender documents going forward.

Standard Terms & Conditions

Our standard contract terms now require all our suppliers to:

  • Prepare and deliver an annual slavery and human trafficking statement 
  • Maintain a complete set of records to trace the supply chain of all services provided to UCL in connection with the contract 
  • Implement annual sub-contractor audits  
  • Implement a system of slavery training for their employees.

Impact Analysis

UCL has developed an impact analysis exercise, through NETpositive.

This is a quick exercise which enables the environmental, social and economic impacts of a purchase be taken into consideration as part of the purchasing decision.

Templates for the exercise have been made available to staff on the Sustainable UCL webpage, with guidance on how to use it and example analyses.

Assessing Risk

Risk assessments

As stated in the last update, we manage our suppliers and risks within specific categories, through the Defra Prioritisation Exercise; this evaluates our purchasing categories against social risks adapted from the ETI Base Code.  

The output generates a risk score from 1 to 5 for each spend category, which allows resources to be prioritised on the highest risk. Our high categories (level 4 and 5) are:

A Audio-Visual & Multimedia  
H Janitorial (Cleaning) 
K Computing 
C Catering 
E Agriculture/Fisheries/Forestry/Horticulture 
F Furniture 
P Printing 
S Stationery (Office Supplies) 
U Health & Safety & Security 
V Vehicles, Fleet Management 
W Estates & Buildings 

Category action plans

We have developed tailored action plans for these highest risk categories which include assessing high risk products within them, monitoring approved contracted suppliers, and road-mapping where contract terms could be reviewed. 


Engagement, training and collaboration

What we are doing:

We are planning to offer workshops on Modern Slavery to our supply chain, and to our local communities
We have issued fact sheets regarding the act and we will continue to raise the profile of Modern Slavery within the company and supplier database
We have a policy to deliver training for all 5000 employees on Modern Slavery 

What our suppliers are doing:

Each of our suppliers have made a statement and a policy on Modern Slavery which we monitor on an annual basis as part of our ISO9001
We offer help/advice to all vendors on Modern Slavery and the ETI base code. We provide training for our goods and services vendors
Supplier Engagement

Since the last update we contacted our top 100 suppliers by spend, informing them about the Netpositive tool, which allows UCL to offer free bespoke sustainability action plans to our suppliers. We now have over 1,200 suppliers on the NetPositive tool, 400 more than last year.

We have identified all of UCL’s approved contracted suppliers and recorded whether they are on the NetPositive supplier tool. Of the 244 suppliers identified, 118 (48.4%) are on the tool while 126 (51.6%) are not. We will engage those not on the tool to register and develop action plans.

The tool also allows our suppliers to communicate actions they are taking in managing their sustainability impacts, including exploitation in supply chain.

Staff Engagement

We consult and engage with our staff and the recognised trades unions on a variety of employment issues.  We undertake regular staff surveys and we consult widely on changes to our employment policies and practices.   

In the last year we have worked with the trade unions on a dispute over our pension scheme; and to harmonise the terms and conditions of our major sub-contractors.  

We also pay the London Living Wage, and we are working towards the Mayor of London’s Good Work Standard award. 


We want to ensure our statements are widely available to not only demonstrate our work but provide information for other organisations to develop their own actions.  

We have uploaded UCL’s previous statement updates to statement registries to ensure it is available:  

This year we have supported a PhD student from Bath University, researching higher education and Modern Slavery Statements. This entailed a virtual interview discussion on UCL’s approach to writing our Modern Day Slavery Statements. 



The year ahead we commit to:    

Managing risk

  • Ascertain which Modern day Slavery questions developed can be put into the stock tender documents, meaning all tenders will be required to ask them. 
  • Record whether our approved contracted suppliers have a statement and are members of Sedex, a supply chain audit sharing network platform. 
  • Implement the actions plans developed for level 4 & 5 risk categories.  
  • Develop actions plans for lower risk categories. 
  • Develop a University Modern Slavery audit template document to enable procurement to conduct virtual audits of UCL suppliers. 
  • Carry out at least one pilot supplier audit which has Modern Slavery as its central theme. 
  • Report on how our new sustainability strategy supports eradicating exploitation and slavery in our supply chain. 
  • Record completed impact analyses.  
  • We shall work with our academic experts to identify ways to measure the effectiveness of our work to eradicate exploitation and Modern Slavery.  
  •  Increase the use of the Impact analyses exercises for purchasing decisions. 


  • Ensure 90% of our approved contracted suppliers are signed onto the NETpostive supplier engagement tool and completed a meaningful sustainability action plan. 
  • Explore developing a questionnaire to send to our main suppliers, to gain more insight into their stance, processes and procedures on Modern Slavery. 
  • Approach our approved contracted suppliers who demonstrate innovation and best practice in addressing Modern Slavery, to share knowledge and develop collaboration. 
  • Engage key buying / purchasing staff to understand training needs for Modern Day Slavery. 
  • Research additional training from external resources on slavery and exploitation, and promote at UCL. 
  • Develop procurement Mandatory training, to be completed before staff have access to procurement and purchasing at UCL. This would include information on Modern Day Slavery and Exploitation. If an extra module is not possible, to add Modern Day Slavery to UCL’s existing Sustainability Training module.

Fiona Ryland
Chief Operating Officer