Modern Day Slavery Statement Update 2020-21
This year has seen further collaboration across UCL’s Procurement and Sustainability functions to address Modern Day Slavery and exploitation.
Since the last statement, we have conducted a number of substantial procurements where Modern Day Slavery has been carefully reviewed (Travel Management services, on-site security services), appointed an external auditor to review our processes and policies and implemented a more detailed action plan to improve our approach to Modern Day Slavery. We have reviewed the Modern Day Slavery statements of our suppliers with an annual turnover in excess of £36m per annum, and those with less turnover who have made voluntary statements.
We continue to review our processes and are encouraging all new suppliers to either subscribe to UCL’s supplier engagement tool, NETpositive, or to share their Environmental, Social and Governance policies with us. We are continuing to rationalise our supplier base to promote contract compliance and improved supplier performance monitoring.
All new staff complete the mandatory Sustainability Induction course which includes a module highlighting Modern Day Slavery and exploitation. We provide a list of recommended training courses for all staff, which includes Modern Day Slavery training. During the period 20/21 890 (47%) of new staff completed this course.
The purpose of this document is to provide an update on UCL's commitment to identify, prevent and mitigate Modern Day Slavery within our supply chain.
In 2016, UCL published its first Modern Day Slavery Statement, followed by annual updates. This is our update for the financial year ending 31 July 2021. This work has primarily been led by Commercial & 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 15,000 staff and 48,000 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:
- Books and printing;
- Catering services;
- Electronics (computers, audio visual etc.);
- Facilities management (hard and soft);
- Laboratories and medical services;
- Security services;
- Travel management services;
- Waste and recycling services.
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:
- Within catering, a sector high for reports of UK labour exploitation, we purchase fish, meat and vegetables. 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 and our preferred catering contractor has rigorous supply chain controls in place to support our Sustainability strategy and commitments in this area;
- 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. We have worked with our suppliers to achieve accreditation from the London Living Foundation and to embed this as a contractual requirement for those suppliers providing staff regularly to UCL sites;
- 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. As each contract has been re-procured we have worked with our suppliers to ensure that Modern Slavery risks are addressed directly and via their supply chains. We have worked with our suppliers to achieve accreditation from the London Living Foundation and to embed this as a contractual requirement for those suppliers providing staff regularly to UCL sites;
- We purchase electronic equipment, including IT hardware and AV equipment, with parts (including minerals) sourced globally and predominantly manufactured in Asia. We have introduced a standard End User Hardware policy to ensure the sourcing of hardware aligned to our sustainability strategy with the co-operation of the original equipment manufacturers.
- Assessing Risk
We have managed our suppliers and risks within specific categories through the Defra Prioritisation Exercise. This evaluated our purchasing categories against social risks adapted from the Ethical Trading Initiative (ETI) Base Code but has since been archived.
The output generated 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) remain:
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 plans for these categories, to support focused work in each to understand and tackle risks. These are reviewed annually.
We are also working to evaluate the Modern Day Slavery statements of our current and new top suppliers based on spend against the guidance from UKUPC based on the UK Government’s Transparency in Supply Chain’s practical guide, issued in 2017.
Managing the risk of Modern Day Slavery (actions taken 2020/21)
Since the last statement, we have worked to achieve London Living Wage as a reflection of our commitment to staff working on our sites and also worked with our supply chain to understand their approach to Modern Day Slavery. We requested an audit of our policies by KPMG, to help us improve our approach, policies and procedures to manage the risk of Modern Day Slavery within our supply chain. As part of this we continue to review where we must add further Modern Day Slavery requirements. Specific actions we have implemented are outlined below in more 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.
- Our Market Pay Policy is 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.
- UCL’s 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.
- Our Safeguarding Children and Adults at Risk Policy ensures that staff and students know how to report any safeguarding issues including modern slavery.
- Our new Supply Chain Policy sets our principles and practices in the responsible acquisitions of goods and services.
- The Fairtrade Policy sets out UCL and Students’ Union UCL’s support of the principles, ethos and aspirations of Fairtrade and commits to using, selling and promoting Fairtrade products through all of our outlets and relevant activities.
- Our Sustainability Strategy includes objectives on supplier engagement, procurement training for staff and modern slavery auditing by 2024.
- Procurement Process
Enhanced questions for due diligence
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 competitions. These were Master Vendor (temporary recruitment), provision of personal protective equipment (frequently shipped from China hence high risk) travel management services, and on-site security services.
Supplier database and adherence to UCL Values
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.
In some spend areas we have a high number of suppliers who provide the same or similar products/services and are not managed via Commercial & Procurement Services or on contract. In these areas, we are rationalising our supplier base, to reduce risk and enable more effective monitoring of suppliers’ performance. Suppliers have been assessed against the steps taken to support anti-exploitation and prevent slavery. These suppliers are contracted against UCL’s standard contract terms which have Modern Day Slavery reporting requirements or bespoke agreements with appropriate Modern Day Slavery requirements. Within Communications and Marketing we removed several thousand suppliers and put in place updated contracts, and NETPositive Action Plans were completed by all suppliers for Creative Services. We have mandated the use of a supplier for merchandise (a high risk area) with SEDEX (transparency throughout the supply chain) accreditation and removed other suppliers that do not fulfil these standards.
We continue to review other categories of spend.
Responsible Procurement Code
We initiated an external verification audit (self assessment and joint) of the Procurement and Sustainable UCL teams by a third party auditor (Anthesis). We achieved an overall score of 78%/GOLD which represented an improvement on previous audits. We are now focused on an action plan to achieve Platinum at the next audit which will align us to Level 3 (Practice) on the Sustainable Procurement in Government Flexible Framework.
Our catering services are provided by a single supplier with c. 130+ staff on site. We continue to focus on sustainability within UCL catering services. Our provider has a supply chain compliance programme that “consists of structured contractual documentation (requiring suppliers to commit to complying with all relevant laws and regulations, including those relating to modern slavery and human trafficking) and a cyclical checking programme to ensure all parties uphold their commitments in line with our values” which are aligned with UCL’s values. Via this programme we are assured that our catering supply chain is compliant or working towards compliance with the requirements of the Modern Day Slavery Act as they apply in relation to the size of each suppliers' business. The catering provider has focused on reviewing non-core suppliers to ensure compliance.
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
We have also focused on cleaning as a high risk area for Modern Day Slavery. All of our cleaning providers are committed to paying the London Living Wage for staff on UCL’s site. Our main cleaning provider (circa 420 staff on site) has also formed a Modern Slavery Strategic Supplier Forum at a corporate level “to highlight risks, share best practice and agree common commitments to tackle modern slavery within their respective organisations.” The aim is “to draw together common experiences and identify ways of working together to tackle some of the underlying issues of modern slavery within both local and global supply chains.” As we review our supply chain expertise such as this will benefit UCL.
Personal Protective Equipment (PPE)
The coronavirus pandemic necessitated urgent purchasing of PPE. We approached our existing office supplies’ provider as we were familiar with the processes in place already to assess their suppliers for modern day slavery and exploitation risks and were assured as to their compliance with the ETI Base Code and ILO’s International Labour Standards. We were also conscious to manage volatility of supply which meant a variety of manufacturers were involved, thus increasing possible risks. Therefore we asked very specific questions around the manufacture and supply of face coverings, auditing of third party factories and certifications.
During 2021, we have competed to appoint a new provider for on-site security services. This is an area that is acknowledged to be a medium level risk in terms of labour and rights violations. Processes to ensure compliance with the requirements of the Modern Day Slavery Act and best practice were a key component of the selection criteria. We will continue to work our supplier post award to ensure that best practice is adhered to and promoted, we estimate circa 247 security staff operate on our sites.
During the procurement for a new Travel Management provider, all suppliers were evaluated against enhanced questions regarding Modern Day Slavery focusing on risk in the end-to-end supply chain, risk assessments thereof and verification of their suppliers against the ETI Base Code. The competition for a new Travel Management provider means that we have a supplier with a zero tolerance to slavery and human trafficking approach, who requires “all supplier and partner organisations we work with to operate to the highest standards both internally and in managing their own supply chains and to share our values and respect for human rights.” The supplier takes a robust approach to reviewing their supply chain, has “no reports of any incident in our supply chain (or of any human trafficking offence). We have not had to take any action (termination of contract or otherwise) against any supplier because of the findings of the modern slavery questionnaire or otherwise in relation to modern slavery in this past year.” The Travel provider also has a Responsible Sourcing Code that, “sets out requirements on human and labour rights and we aim to ensure that our suppliers understand and collaborate with the criteria in the Code.”
Waste and Recycling Services
In response to news that examples of modern slavery occurred in a UK waste sorting centre, we assured our supply chain for compliance and worked with our provider to understand the increased measures implemented across the industry as a result of this case.
Engagement, training and collaboration (actions taken 2020/21)
- Collaborating Actions
We invited KPMG to review our policies and practices during 2021 to ensure that we identify areas for meaningful improvements. A detailed action plan has been created to follow through on these planned 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.
We continue to upload UCL’s previous statement updates to statement registries to ensure it is widely available. TISC Report Registry is still operating and we have uploaded our statement to the Modern Slavery Statement Registry.
We continue to utilise the NETpositive tool and have mandated the provision of action plans or ESG policies to be provided by all new suppliers.
- 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. 890 staff (47% of all new starters) completed this course between August 2020 and July 2021.
- Supplier Engagement Actions
The NETpositive tool, which allows UCL to offer free bespoke sustainability action plans to our suppliers, now has 1,500 suppliers, a further increase of 300 from the previous year. We continue to get more of our approved contracted suppliers onto the tool.
We will build on the progress we’ve made so far and have signalled some of our planned areas of focus in this Statement. We have developed a specific Modern Slavery Action Plan based on areas identified by the third party auditor.
- We will set up a Governance forum specifically focused on Modern Day Slavery, to promote best practice across UCL sponsored by our Pro Vice-Provost (Equity & Inclusion) with subject matter experts (UCL academics) from Construction, International Politics and Policy and Laws as well as Commercial & Procurement and Sustainability.
- We are working with our Learning & Development function to report completion rates for the mandatory training modules to improve performance under the sponsorship of the Vice-President (Operations) to achieve greater compliance.
- Continue to work with our approved suppliers to share knowledge and develop collaboration.
- Develop UCL supplier engagement/awards, with possibility of highlighting anti-slavery and exploitation as a key area.
- Continue to raise awareness of Modern Slavery across other engagement activities, such as UCL’s Fairtrade Fortnight promotions.
- Develop action plans for our categories with risk scores 3 and below, as we have already done with level 4 and 5.
- 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.
- Promote the London Living Wage
- Request and review sample factory reports from our suppliers who use SEDEX supply chain tool.
- 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
- 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
Chief Operating Officer
Written: 9 December 2021