Modern Day Slavery Statement Update 2019-20
This year has seen further collaboration across Procurement and sustainability functions to address Modern Day Slavery and exploitation. UCL’s Sustainability Strategy is now one year old, and the Modern Day Slavery and wider supply chain objectives it contains have supported this work.
Since the last statement, UCL has conducted a number of important tenders: Catering, Print and Travel Services, which have all included enhanced Modern Day Slavery questions as part of the selection process. The catering contract has detailed requirement for responsible sourcing and supply chain management.
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. Furthermore, we have started to collect greater sustainability data on our approved contracted suppliers, including checks for Modern Day Slavery Statements and being signed up to the NETpositive tool. Additionally, we identified where we have a high number of suppliers not on contracts, and started to rationalise our supplier base, which will reduce risk and enable more effective monitoring of supplier's performance.
For staff engagement, the mandatory Sustainability Induction course for all new staff has been updated and includes a responsible procurement section which highlights Modern Day Slavery and exploitation as issues for purchasing at UCL. We have reviewed sources of sustainable procurement training and created a list of recommended training courses for all staff, which included Modern Day Slavery training.
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 2020. This work has primarily been led by Procurement Services and Sustainable UCL. Since the first statement, we have committed to the following principles:
- 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.
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.
As a global University with a diverse community, we have an opportunity to inspire sustainability action from local to international scale. This is delivered through our Sustainability Strategy 2019-2024, with The Sustainable Development Goals (SDGs) providing the framework. Our approach is underpinned by three Foundations: we inspire action, we are run sustainably, and we shape the debate. The Strategy sets out three signature campaigns – Positive Climate, The Loop and Wild Bloomsbury, which bring together our teaching, research and operations to show that a sustainable future is possible. The Loop is specifically our approach to consumption, resource use and responsible procurement.
UCL's main campus is in the heart of Bloomsbury, London, however we have buildings across the UK.
UCL has built a new campus at Queen Elizabeth Olympic Park, to form part of a wider education and cultural quarter in the capital due to open Autumn 2022.
UCL 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,
- 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. We conduct risk analysis to understand likelihood of exploitation in different categories and prioritise action according to this risk.
- 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. We want to rationalise our supply base in these areas, to reduce risk and allow for focused supplier engagement.
- 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. Our Healthy and Sustainable Food Policy includes requirements for these products/ingredients.
- 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. Whilst London Living Wage is a requirement in our large construction contracts, we will do further engagement and checks during the contract to understand our supplier's policies and procedures to ensure this requirement. We should also highlight any good practice/learnings for future contracts/tenders.
- 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. All of our catering, cleaning and security contracts are required to pay London Living Wage, and we will do enhanced vetting when these contacts are renewed/tendered.
- Assessing Risk
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
We have created action plan for these categories, to support focused work in each to understand and tackle risks. These will be reviewed annually.
Managing the risk of Modern Day Slavery (actions taken 2019/20)
Since the last statement, our Sustainability Strategy delivery has enabled greater collaboration on supply chains and Modern Day Slavery. Having identified our policies, strategies and procurement processes to assess suppliers and purchasing decisions, we have identified where we must add further Modern Day Slavery requirements. We have also collected great data from suppliers and developed our risk assessment exercises to ascertain those high risk areas where we should focus our resources, in order to have the greatest impact. Our catering provision was a focus contract for this period. Below lists our specific actions in detail:
- 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:
- Our Human Resources Policies set out workplace rights at the University, including ensuring our new staff have the right to work in the UK.
- Market Pay Policy agreed in partnership between UCL and the recognised trade unions, Unite (formerly Amicus), AUT and UNISON. This ensures UCL pay for UCL staff reflects the sector rates.
- Prevention of Bullying, Harassment and Sexual Misconduct Policy assists in maintaining a healthy working environment where unacceptable behaviour is easily identified, challenged and stopped. It is intended that this will improve staff performance, raise morale, reduce stress and aid retention.
- Safeguarding Children and Adults at Risk Policy ensures that staff and students know how to report any safeguarding issues including modern slavery.
- Procurement Strategy (2016-20) (PDF) and Purchasing Procedures/Policies sets our principles and practices in the responsible acquisitions of goods and services.
- Fairtrade Policy for UCL and Student’s Union UCL to support the principles, ethos and aspirations of Fairtrade and commit to using, selling and promoting Fairtrade products through all of our outlets and relevant activities.
- Sustainability Strategy which includes objectives on supplier engagement, procurement training for staff and modern slavery auditing by 2024.
- Procurement Process
Our additional standard questions for our tender process, utilising best practice (Government’s Transparency in Supply Chains Guidance and the Ethical Trading Initiative’s Guidance) have been used and scored as part of our large high-risk tenders. These were Catering, Printing Services, Vulnerability Assessment Software & Associated Services and ULT Freezer tenders.
In some spend areas we have a high number of suppliers who provide the same or similar products / services and are not managed through a procurement framework. In these areas, we want to rationalise our supplier base, to reduce risk and enable more effective monitoring of supplier's performance. As part of this rationalisation, suppliers will be reviewed for their efforts on anti-exploitation and slavery, and only those deemed suitable will be approved onto UCL’s standard contract terms (which have modern day slavery reporting requirements). Procurement Services have conducted a review of all our Corporate Services suppliers and will review other spend areas going forward.
We have created a database of UCL contracted Suppliers, which records information on the sustainability performance of our suppliers. This database provides the following information:
- Record whether suppliers have a Modern Day Slavery Statement
- Comments on the quality of Modern Day Slavery Statement
- Records if the suppliers are Sedex Members
- Shows if the supplier has signed up and have an action plan on NETpositive Supplier Engagement Tool
This database will be used to begin monitoring our contracted suppliers, and we will engage suppliers who are not on NETpositive and/or do not have a Modern Day Slavery Statement.
Responsible Food Sourcing
Since the last statement, UCL has focused on sustainability within UCL catering services, including delivering notable achievements on responsible sourcing and supply chain management:
UCL catering contract achieved Sustainable Restaurant Association Food Made Good 2-star award through a site-based audit. The scheme criteria includes responsible sourcing and valuing staff.
In a joint partnership, UCL and UCL Union were awarded the Fairtrade University and College Award, demonstrating promotion of Fairtrade sourcing. We have begun selling Tony’s Chocolonely in outlets, with promotional events on campus.
UCL has adopted a UCL Healthy & Sustainable Food Policy, which all UCL suppliers must comply with.
The Policy review has included certifications to support ethical sourcing of products which have risk of exploitation. These certifications include requirements for fair labour practices:
- Marine Stewardship Council (MSC) - Fish
- Roundtable on Sustainable Palm Oil (RSPO) - Palm oil containing products
- Round Table on Responsible Soy (RTRS) or ProTerra - Soy containing products
Engagement, training and collaboration (actions taken 2019/20)
We continue to utilise the NETpositive tool and have increased suppliers signed up. We have also focused on providing training resources for staff. Below lists our specific actions in detail:
- Supplier Engagement Actions
The NETpositive tool, which allows UCL to offer free bespoke sustainability action plans to our suppliers, now has 1,200 suppliers, a 300 increase from the previous year. We continue to get more of our approved contracted suppliers onto the tool.
- Staff Engagement Actions
The mandatory Sustainability Induction course for all new staff has been updated and includes a responsible procurement section which highlights Modern Day Slavery and exploitation as issues for purchasing at UCL.959 staff completed course between August 2019 and July 2020.
Since the last statement we have reviewed sources of sustainable procurement training and created a list of recommended training courses for all staff. This includes training on Modern Day Slavery and Exploitation which is suitable for a range of roles and needs within UCL, from general staff to buyers and procurement professionals.
- Collaborating Actions
We want to ensure our statements are widely available to not only demonstrate our work but provide information that may support other organisations to develop their own actions.
As members of SUPC, we attend the Responsible Procurement Group meetings.
We continue to upload UCL’s previous statement updates to statement registries to ensure it is available; TISC Report Registry is still operating, but The Modern Slavery Registry has been replaced by The UK Government’s Modern Slavery Statement Registry. We will ensure our new statements are uploaded to this new registry.
We will build on the progress we’ve made so far and have signalled some of our planned areas of focus in this Statement. Listed below are specific actions for 2021 and beyond.
- Develop actions plans for our categories with risk scores 3 and below, as we already done with level 4 and 5.
- Conduct a virtual audit of our top 20 suppliers to ensure compliance with Modern Day Slavery Act requirements.
- Carry out at least one detailed pilot supplier audit which has Modern Slavery as its central theme.
- Review industry certifications / schemes which support ethical labour practices, which could be utilised in tenders / supplier engagement.
- Engage KPMG to undertake a supply chain assurance audit, as part of UCL’s internal audit function.
- Approach our approved contracted suppliers who demonstrate innovation and best practice in addressing Modern Slavery, to share knowledge and develop collaboration.
- Develop UCL supplier engagement / awards, with possibility of highlighting anti-slavery and exploitation as a key area.
- Include Modern Day Slavery awareness into other engagement activities, such as UCL’s Fairtrade Fortnight promotions, to raise profile across UCL.
- Become an accredited Living Wage Employer, through The Living Wage Foundation, which recognises UCL paying all staff the Living Wage or London Living Wage as a minimum.
- Conduct a GAP analysis of UCL’s Modern Day Slavery work programme and identify priorities/ resources.
- Commission an external audit of UCL supply chain assurance.
- Work with our academic experts to identify ways to measure the effectiveness of our work to eradicate exploitation and Modern Slavery.
- 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.
- NETpositive Tool strategically utilised and embedded into supplier management.
Chief Operating Officer