Commercial and Procurement Services


Modern Day Slavery Statement Update 2022-23

This is an update on the work UCL has undertaken in 2022-23, to value the people working at UCL and within our supply chains, and to protect them from slavery and exploitation.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year beginning 1 August 2022 ending 31 July 2023 (FY22/23). It was approved by Council on 15th February 2024 and signed by the President and Provost of University College London company number RC000631 (“UCL”) on behalf of UCL on 23rd February 2024.

Companies within the University College London group can be found in Appendix 1.


This Modern Day Slavery Statement outlines University College London's and its wholly owned subsidiary, UCL Consultants Limited’s (UCLC) ongoing commitment to combating modern day slavery and human trafficking within its operations and supply chains.  Throughout this statement ‘UCL’ also includes UCLC, unless where UCLC is explicitly stated.

This document provides an overview of UCL’s structure, business, and supply chains, detail its policies and governance, present its goals and key performance indicators (KPIs), and reports on actions taken in 2022/23. Additionally, it outlines UCL’s goals for FY23/24, emphasising the importance of modern day slavery awareness, risk mitigation, and responsible sourcing.

During the period 1 August 2022 – 31 July 2023 (FY22/23) UCL has continued to focus on issues of modern day slavery and exploitation of people in its supply chains through its Commercial & Procurement Services and Sustainability functions.  2022-23 was the first year that UCLC was required to produce a Modern Day Slavery Statement.

Steps taken during FY22/23 to ensure that slavery and human trafficking is not taking place include:

  • Implemented changes via an Action Plan sponsored by the Vice-President Operations.
  • Promoted awareness of the risk of Modern Slavery and transparency of supply chains, across UCL via its mission and values and through its supply chain.
  • Maintained Living Wage Foundation accreditation and continue to promote this amongst UCL's supply chain.
  • Registered its Modern Day Slavery Statement with UK Government’s Modern Slavery Statement Registry and TISCreport and used TISCreport (Transparency In Supply Chains Platform) to assess and monitor compliance within its supplier base, encouraging suppliers to register.
  • Based on an analysis by TISCreport.org 672 suppliers in UCL’s supply chain are required to submit a Modern Day Slavery Statement.  The TISC report.org analysis showed 83 (12%) suppliers as potentially non-compliant due to non-visibility of a Modern Day Slavery Statement on their websites. A further review of these potentially non-compliant suppliers determined that 63 were confirmed as not being required to submit a statement or were no longer active suppliers with UCL.
  • Work is underway with these suppliers to determine whether they are required to publish a statement.
  • Enrolled and encouraged our supplier to enrol with Open Apparel Registry (OAR).
  • Reviewed the risk profile of suppliers with whom UCL has low value spend.
  • Reviewed UCL's supply base and consolidated suppliers via Preferred Supplier Lists whereby suppliers are contracted against UCL’s standard contract terms which include Modern Day Slavery reporting requirements.
  • Assessed and managed risk for those categories at highest risk of modern slavery including - Audio visual & IT Equipment, Catering, Cleaning, Construction, Recruitment agencies, Security, Travel, and Waste management.
  • Enhanced due diligence processes using enhanced questions and supplier management processes.
  • Promoted staff and supplier engagement through the ongoing mandatory training course, Change Possible which includes a module highlighting modern day slavery. A further 2,052 staff have completed this course in FY22/23. 



UCL remains resolute in its mission of preventing and eliminating any instances of modern day slavery and human trafficking within its supply chain. At UCL, dedication to safeguarding and upholding human rights is at the core of its mission. UCL maintains a zero-tolerance stance towards any manifestation of slavery or human trafficking. This statement reflects UCL’s dedication to transparency, ethical business practices, and human rights. As a leading institution, UCL recognises its responsibility to ensure that its actions align with its values.

In 2016, UCL published its first Modern Day Slavery Statement, followed by annual updates. This document is the update for the financial year ending 31 July 2023. This work has primarily been led by Commercial & Procurement Services and Sustainable UCL.

Since the first statement, UCL has committed to the following principles:

  • Commitment to better understand its supply chains and work towards greater transparency and responsibility towards people working in them.
  • Raise awareness of how to identify and report suspected Modern Slavery.
  • Monitor supply chains that have been identified as a potential risk and take appropriate action as necessary.
  • Implementation and enforcement of effective systems and controls to tackle slavery and human trafficking which may be taking place in our supply chains.
  • Provide appropriate training to our staff to raise awareness of Modern Slavery and how to identify potential risks.

UCL’s Structure, Business, and Supply Chains

UCL is a multidisciplinary university with 16,000 staff and 50,000 students from diverse backgrounds spanning 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’s activities and research are guided by its Sustainability Strategy and the United Nations Sustainable Development Goals (UN SDGs).

  • UCL is comprised of 11 Faculties.
  • UCL is an exempt charity, in accordance with the Charities Act 2011 and receives funding from multiple sources to support its activities and research.

UCL Consultants Limited (company number 03332258) is a wholly owned subsidiary of UCL. It is led by its Managing Director and reports to a Board of Directors which meets quarterly and which is attended by a representative of UCL’s UMC.

Our business

UCL endeavours to uphold its mission as a diverse intellectual community, actively engaged with the wider world, and dedicated to effecting positive change. It aims to be recognised for its profound and critical thinking, which holds widespread influence. Additionally, it seeks to continue to excel in seamlessly integrating its educational, research, innovation, and entrepreneurial endeavours, all for the long-term benefit of humanity.

As a global university with a diverse community, UCL has the unique opportunity to inspire sustainable actions on both local and global scales. This is achieved through the implementation of its Sustainability Strategy (pdf) for the years 2019 to 2024, underpinned by the United Nations Sustainable Development Goals (UN SDGs), and developed in consultation with UCL staff.

UCL is governed by Council, responsible for overseeing the management and administration of UCL, as well as guiding its affairs, while considering advice from the Academic Board regarding academic policies. The Council is responsible for endorsing UCL's mission, strategic vision, and long-term academic and business plans. The Council delegates authority to the Provost, who serves as the Chief Executive, overseeing the academic, corporate, financial, estate, and human resources management of UCL. The governance structure and the functions of the Council are transparent and accessible to the public.

In June 2021, an external management consultancy, KPMG, conducted an effectiveness review of UCL’s Modern Day Slavery Policy and practices. Subsequently, an Action Plan was developed, with sponsorship from the Vice President of Operations. This Action Plan was successfully implemented and closed in October 2022, in collaboration with KPMG.


  • 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 which opened fully in September 2023.
  • UCL works with partners all over the world.

UCL’s Supply Chain

UCL spent around £1.1bn inc. VAT during FY22/23, procuring goods and services globally. Its supply chain encompasses third-party suppliers covering a wide range of products and services, as well as research, professional services and teaching.

UCL’s commitment to sustainable practices is at the core of how it manages its supply chain activities, significantly impacting UCL's financial stability, reputation, risk management, and Corporate Social Responsibility (CSR) goals. It is dedicated to forming partnerships with suppliers who not only share its values and principles but also exhibit innovation and competitiveness through its Commercial & Procurement Services function.

UCL procures a diverse array of goods and services that are essential for the efficient operation of the university and the facilitation of research. These requirements span various supply chains, including:

  • Books and printing
  • Catering services
  • Construction
  • Electronics (computers, audio visual equipment, etc.)
  • Facilities management (both hard and soft services)
  • Furniture
  • Laboratories and medical services
  • Security services
  • Stationery
  • Travel management services
  • Waste and recycling services

Goods and services are sourced from suppliers around the world, encompassing a wide spectrum of entities, from individuals and local small and medium-sized enterprises (SMEs) to large multinational corporations. As a part of supplier due diligence, UCL continues to document the head office locations of suppliers and their policies, particularly in areas such as modern day slavery and human trafficking. To comprehensively understand the likelihood of exploitation within different supplier categories, UCL conduct thorough risk analyses, allowing it to prioritise action based on these risks. ULC partners with several Tier 1 organisations (those directly contracted with us), working with them to closely map and examine their supply chains, proactively identifying potential risks to further underscore its commitment to sustainability.

Modern Day Slavery and Human Trafficking Policies

Addressing modern day slavery is a priority for UCL. As part of its commitment to fair working practices for all, UCL asks suppliers to comply with the following policies which support fair working practices for all and ensure it buys ethically. It further explains where UCL Consultants Ltd’s policies differ from UCL’s.

Policies and Governance

PolicyPurposeOwned byPublishedUCL Consultants Ltd's policy position - where different
Institutional StrategyUCL 2034 and 2022-2027 Strategic Plan - sets out a clear vision for UCL, with sustainability embedded throughoutProvost, Sustainability Committee2023 
Sustainability Policy (docx)UCL has a Sustainability Policy that sets out its high-level sustainability objectives. This Policy has been signed off by UCL President and Provost Dr Michael Spence AC and is reviewed annually by the Sustainability Committee as part of the annual ESMS Management ReviewProvost, Sustainability Committee2022 
Energy Policy (pdf)To establish a framework for energy management at UCL, with the aim of involving the entire UCL community in addressing energy-related impacts and opportunities.Sustainability2019 
Human Resources PoliciesSets out workplace rights at the University, including ensuring our new staff have the right to work in the UKHRMultiple
UCLC has in place a set of HR policies which are broadly in line with UCL’s, setting out workplace rights and ensuring RTW compliance
Market Pay PolicyIs 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 and is extended to outsourced staff (such as catering, cleaning and security staff)HR2010UCLC operates a commercial approach to setting pay rates, which sits outside HERA but which is benchmarked broadly to UCL equivalent positions and to commercially comparable operations. Pay is reviewed and set by a sub-group of the Board of Directors (the Remuneration Committee) and a PRP system is in place, the principles of which are reviewed and approved annually by the Board
Prevention of Bullying, Harassment and Sexual Misconduct PolicyAssists in maintaining a healthy working environment where unacceptable behaviour is easily identified, challenged and stopped this is intended to improve staff performance, raise morale, reduce stress and aid retention and we expect all of our suppliers to have similar policies in placeProvost Equality, Diversity & Inclusion  
Sustainability StrategyIncludes objectives on supplier engagement, procurement training for staff and modern slavery auditing by 2024Sustainability2018 
Fairtrade PolicySets 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 its outlets and relevant activities (particularly applies to its catering partner)Sustainability2018 
Supply Chain PolicySets our principles and practices in the responsible acquisitions of goods and servicesCommercial Director2021UCLC procures largely through UCL systems and does so for all high-risk suppliers as identified in the MDS statement. In respect of the significant instances where it does not, this is in relation to its software and cloud services for its case management and financial systems and this is done in consultation with UCL ISD

Summary of Governance

UCL demonstrates a continuous dedication to its environmental responsibilities. The Provost and Council channel sponsorship, leadership, and resources toward minimising UCL's environmental footprint through the University Management Committee (UMC).

Additionally, UMC conducts an annual review of UCL's sustainability report.

The Sustainability Committee has been established to oversee the development and management of UCL's approach to sustainability. In particular, the delivery of the Sustainability Strategy and the Sustainable Finance Framework.

The committee is the forum for all key stakeholder representations (including students) to meet, review and agree key sustainability initiatives, propose, targets and monitor performance.

The Sustainability Committee is a sub-committee of the UCL Operations Committee.

Goals and Key Performance Indicators (KPIs)

UCL’s KPIs focus on:

Utilising the previous audit of its policies conducted by KPMG, UCL has monitored progress against an action plan that was jointly developed to reinforce the approach, policies, and procedures aimed at mitigating the risk of Modern-Day Slavery within its supply chain.

The specific actions that have been put into effect are outlined in this Statement:

  • Improved due diligence of low spend goods/services
  • Improved policies associated with key risk areas
  • Enhanced supply chain mapping
  • Introduction of Key Performance Indicators
  • Processes in support of Supply Chain Policy
  • Collaboration and approved contracted suppliers
  • Enhanced training

UCL has further advanced transparency by sharing its Modern Day Slavery Statement on both the UK Government's Modern Day Slavery Statement Registry and continuing to work closing with the Transparency in Supply Chain (TISC) platform. In addition, UCL has assessed its supply chain’s compliance in alignment with the TISC dashboard and actively encouraged suppliers to register on the platform. UCL’s commitment to sustainability is unwavering, and it is mandatory for all new suppliers to provide action plans or ESG (Environmental, Social, and Governance) policies. UCL also actively promote best practices throughout its supply chain network.

Reporting and Assessing the Risk of Modern Day Slavery (Actions Taken 2022/23)

Living Wage

UCL continues to maintain Living Wage Foundation accreditation and continues to promote this with its supply chain. As part of its accreditation with Living Wage Foundation UCL conducts annual audits of suppliers to promote pay parity for those suppliers providing staff regularly to UCL sites.

UCL’s terms and conditions of purchase for low value goods and services promote payment of in country living wages.


UCL’s commitment to combat modern day slavery is exemplified by its registration of the Modern Day Slavery Statement with both the UK Government’s Modern Slavery Statement Registry and TISCreport. Through TISCreport.org, in FY22/23 UCL has actively assessed and monitored compliance within its supplier network, while actively encouraging its supply chain partners to join this initiative.

Within UCL’s supplier base, which exceeds 6,000 suppliers, it identified:

  • 672 suppliers eligible to provide statutory Modern Day Slavery Statements, collectively representing £297 million or 39% of UCL's third-party expenditure during FY22/23.
  • Of the 83 suppliers identified as potentially being required to comply but not having provided a statement, 63 were confirmed as not being required to submit a statement or were no longer active suppliers with UCL.  Active engagement is underway with the remaining 20 (3%) suppliers to ensure compliance in 2023-24.

In its pursuit its transparency and compliance, UCL has enrolled itself and actively encouraged suppliers to participate in the Open Supply Hub. N.B. the Open Supply Hub transitioned from the Open Apparel Registry on 2nd November 2022, following its closure on 14th October 2022. This hub offers comprehensive factory-level information on manufacturing plants worldwide, with a primary focus on garment-related products, such as uniforms.

Supplier consolidation

UCL continues to review the risk profile of suppliers with whom it has low value spend. Actions are also in place to review the supply base and consolidate suppliers via Preferred Supplier Lists whereby suppliers are contracted against UCL’s standard contract terms which include Modern Day Slavery reporting requirements.

Assessment of risk

UCL previously evaluated its purchasing categories using risk assessment guidance set out in the UK Government’s modern slavery procurement guidance and risk data from a range of sources, in particular the International Labour Organization’s Global Estimates of Modern Slavery (GEM) (pdf) and the US Department of Labor - List of Goods Produced by Child Labor or Forced Labor.

Risk categories remain as follows:

  • Country of origin
  • Sector
  • Transaction type
  • Business partnership
  • Subcontracting

The highest risk categories (based on risk and spend) therefore are:

  • Audio visual & IT equipment
  • Catering
    - Agriculture/ Fisheries/ Forestry/ Horticulture
  • Cleaning
  • Construction
  • Furniture
  • Health & Safety (Personal Protection Equipment) & Security
  • Printing
  • Recruitment agencies
  • Stationery
  • Vehicles Fleet Management
  • Estates & Buildings

Managing the Risk of Modern Day Slavery (Actions Taken 2022/23)

UCL maintains an ongoing commitment to regularly review action plans as part of annual efforts to comprehend and address any risks effectively. Terms and conditions are clear, explicitly articulating the need to adhere to Modern Day Slavery legislation, as well as UCL’s own comprehensive policies concerning Modern Day Slavery and Human Trafficking.

For UCL’s main Facilities Maintenance contracts, which encompass crucial services such as catering, cleaning, and waste collections, it engages third-party companies for their services. These companies employ a diverse workforce, comprising both UK and non-UK staff.

To address Modern Day Slavery risks comprehensively, UCL has integrated measures directly into each phase of procurement activities. UCL required continued maintenance of rigorous policies and the conducting of regular audits from suppliers across their supply chains, ensuring the highest standards of ethical conduct. Additionally, there are stringent obligations in place to promptly report any breaches or violations, emphasising UCL’s commitment to ensuring ethical practices throughout its supply chain.

Audio Visual (AV) and IT Equipment

UCL purchases electronic equipment, including IT hardware and AV equipment, with parts (including minerals) sourced globally and predominantly manufactured in Asia. Hardware purchases are centralised and standardised via a central supplier – a signatory to the UN Global Compact committed to upholding internationally proclaimed human rights.

UCL’s AV and IT equipment is provided by approved suppliers who have been selected following competition. Part of the sourcing criteria is compliance with Modern Day Slavery legislation. UCL has reviewed the Modern Day Slavery and Human Trafficking policies and Conflict Mineral Statements of its Original Equipment Manufacturers (OEM), the supplier in turn states “We are committed to having transparency in our supply chains to remove slavery and human trafficking.” UCL continues to supplier monitor performance via reporting tools such as Electronics Watch.

UCL’s primary OEM, DELL for desktops and laptops is a founding member of the Responsible Business Alliances (RBA) and has adopted its Code of Conduct.

For IT peripherals UCL uses Jabra speaker devices. The parent company GN Group encourages suppliers to be certified or follow the requirements of SA8000, an international Social Accountability Standard requiring the ban of any form of forced labour. This is assessed through supplier audits including onsite inspections of supplier facilities.


Within catering UCL procures both front of house (retail) and back of house (events and hospitality) food and services. UCL continues to work with its catering providers to support with actively identifying and mitigating the risk of forced labour or human trafficking within the supply chain.  UCL is also committed to sourcing products such as palm oil, cocoa, and sugar cane, which are recognized as high-risk products. In alignment with the UCL Healthy & Sustainable Food Policy, certifications that emphasize ethical sourcing for products susceptible to exploitation, including requirements for fair labour practices have been incorporated:

UCL’s catering services are exclusively provided by a single supplier with approximately 153 staff members on-site for FY22/23. UCL remains focused on its commitment to sustainability in its catering services. UCL’s provider places a high priority on sourcing fresh, local, and seasonal goods whenever feasible, with most of their Tier 1 suppliers being based in the UK. They have outlined that some additional products are sourced from the EU and other parts of the world. UCL’s provider is continuously working to achieve 100% compliance in its supply chain and actively supports the University’s extended suppliers in complying with the Modern Slavery Act 2015.

As outlined in UCL’s supplier's Modern Day Slavery Statement, they mandate their business partners to deliver training to their staff, suppliers, and providers to ensure full compliance with UCL’s values. They go on to state: “To enforce this across our supply chain, we have implemented a supply chain compliance program. Additionally, we have partnered with Authenticate, a supply chain database, where all our suppliers are required to upload their own Modern Day Slavery Policies and commit to complying with our own Modern Day Slavery Policies.” It is important to note that to date, there have been zero reported cases of modern day slavery in UCL's catering supply chain, both directly and through third parties. To maintain its focus on preventing modern day slavery, UCL’s supplier has established the following Key Performance Indicators (KPIs):

  • KPI 1: All employees receive annual Modern Day Slavery Training.
  • KPI 2: All suppliers are mandated to share their Modern Day Slavery Policy and upload it to Authenticate.

Cleaning & Non-Hazardous Waste Collection

UCL’s primary cleaning and waste service provider (683 staff on site) has implemented robust initiatives to combat modern day slavery both within their organisation and across its supply chains. In FY 22/23 these efforts have earned it awards, including the 2022 Footprint Award, highlighting their commitment to tackling modern day slavery.

It has formed and actively leads the BSA Modern Slavery Council, a notable collaborative effort supported by the Cabinet Office and Home Office. The council's mission is to champion anti-slavery practices, and it has recently developed a comprehensive modern day slavery toolkit for companies, which was launched in 2023. This toolkit serves as a practical guide to help organisations identify and eradicate modern day slavery within their operations and supply chains.

In addition to these strategic actions, the provider conducts risk management reviews and audits of its suppliers, assessing the business and processes of over 7,000 suppliers, using a risk rating system. This includes audits of high-risk suppliers, such as security and recruitment agencies, based on information from authorities like the Gangmasters and Labour Abuse Authority. Corrective Action Plans are then established and tracked to ensure compliance. Moreover, it actively engages in ongoing modern day slavery training programs for its teams, with plans to extend this training to front-line staff in 2024. This comprehensive approach highlights its dedication to raising awareness and empowering their workforce to recognise and report potential signs of modern day slavery, fostering a safer and more responsible business environment.


UCL completed a large construction project in FY22/23 in the development of UCL East and continue to work across an ongoing programme of construction projects including the Institute of Neurology – Dementia Research Institute (IoN-DRI), with many contractors and subcontractors working on various construction sites. In the construction industry there is a risk of forced labour being used. UCL has worked with its 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. All prime contractors had and continue to have rigorous modern day slavery provisions in place.


The provision of onsite security services represents a medium-level risk in terms of labour and rights violations. UCL remains committed to working closely with its supplier to ensure the adherence and promotion of best practices. As of the fiscal year 2022/2023, UCL estimates that approximately 243 security staff were deployed at its locations.

UCL’s security services provider maintains their policies that ensure that its supply chain meets the necessary standards. It prioritises working exclusively with subcontractors who can demonstrate their own rigorous recruitment procedures and commitment to relevant laws and legislative guidelines. It continues to offer internal training courses and employee toolbox talks, equipping managers, supervisors, team leaders, and HR professionals with the necessary skills to detect signs of modern day slavery.

As an update for FY 2022/23 it has named Unseen UK as its charity partner in Great Britain. Unseen UK provides safehouses and support in the community for victims of trafficking and modern day slavery.

As part of UCL’s supplier's commitment to these standards, potential suppliers are required to apply specific recruitment techniques:

  • Rigorous Interview Procedures: All applicants continue to undergo comprehensive interviews to confirm that they have personally completed registration forms.
  • Approved Interview Locations: Interviews with job applicants are exclusively conducted at approved locations.
  • Preventing Unauthorised Agents: Measures are in place to prevent unauthorised agents or individuals from introducing job applicants.
  • Reporting Mechanisms: Supervisors and Team Leaders, are required to promptly report any suspicions of illegal activity regarding agents to management and, where necessary, to law enforcement agencies.

Ongoing monitoring procedures for supplier staff following employment to address signs of modern day slavery. Supervisors are trained to pay particular attention to several key factors:

  • Physical Appearance: Close monitoring the physical well-being of their employees, with a focus on potential signs of abuse or malnutrition, ensuring their welfare and safety.
  • Personal Effects and Documentation: Review of employees' personal effects and documentation is a routine practice.
  • Freedom of Movement: Ensuring the freedom of movement of their employees is a priority.
  • Third-Party Influence: Monitoring the influence of third parties on staff to safeguard their rights and ensure that their work environment is free from external coercion or exploitation.

Recruitment Agencies

Recruitment of staff is identified as a high-risk area for modern day slavery. Most of UCL’s temporary labour demand is via a Master Vendor agreement introduced in 2020. Although UCL has subsequently changed suppliers, standards remain consistent – these standards include:

  • Compliance audits of pre-employment checks including eligibility to work, references, qualifications and proof of national insurance numbers per branch.
  • Random checks are used in the UK business to identify where agency workers may be sharing bank accounts, addresses or telephone numbers as this can be an indication of illegal or unethical behaviour. Where accounts are shared, the individuals involved are approached to ensure this is voluntary, e.g. where couples share a bank account. To date no incidents of modern day slavery have been identified.

Similar checks are used for permanent recruitment agencies to reduce the risk of modern day slavery.


The provision of travel management services has been rated as high risk for modern day slavery due to the breadth of services procured from UK and international suppliers. UCL’s travel management provider reviews its supply chain and has a formal escalation process in case serious issues affecting working conditions are found within the supply chain.

Purchasing activities are assessed against principles of accountability and internal controls including but not limited to policies across:

  • Quality Management
  • Environment
  • Ethical Code of Practice
  • Anti-Bribery
  • Modern Day Slavery and Human Trafficking.

During 2022/20223  the travel provider’s suppliers have again not received reports of any incident in the supply chain (or of any human trafficking offence). No action (termination of contract or otherwise) against has been taken in response to the findings of the modern day slavery questionnaire or otherwise in relation to modern day slavery in the same period.

The travel provider has a Responsible Sourcing Code which “embodies our commitment to conduct business with integrity, in all our business relationships and to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. The code 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

UCL differentiates Waste and Recycling Services between non-hazardous and hazardous waste. Non-hazardous waste services are managed by its cleaning supplier as above.

For hazardous waste, UCL’s chosen supplier has been selected due to its adherence to ethical standards and the cascade of these standards through its supply chain including, amongst other things, the mitigation of risks associated with slavery and human trafficking. “We believe that improved awareness is one of our most effective methods to reduce the risk of modern day slavery and with the help of both our employees and suppliers we aim to ensure that there are no opportunities to hide forced labour within our organisation or our supply chain.”

The supplier continues to assess the risk of noncompliance within their organisation and supply chain, where areas are identified, an audit is conducted, which will include a focus on compliance with employment as well as other regulatory and sustainability criteria.

UCL’s supplier uses a supplier on-boarding process including standard due diligence procedures, to assess the suitability of a vendor to provide goods and services against compliance to required standards. This process captures confirmation that they are committed to ensuring that slavery and human trafficking is not taking place within their own supply chain. Desktop audits are conducted as part of supply chain management to provide assurance that suppliers are responsible partners in service delivery. Tier 1 (based on volume of spend and risk) suppliers within the supply chain are subject to twice per year reviews to identify, understand and seek to mitigate risks associated with modern day slavery.

Key performance indicators (KPIs) are used to measure the effectiveness of communicating awareness of core policies and procedures related to the requirements of the Modern Slavery Act, and other actions to seek to ensure that slavery and human trafficking is not taking place in any of its businesses or supply chains.

Due diligence

Enhanced Questions

When procuring goods or services identified as high risk, UCL continues to use best practice additional questions derived from UK Government’s Transparency in Supply Chain’s Guidance.

Supplier management

UCL maintains records of contracted Suppliers including the following information:

  • Modern Day Slavery Statement compliance and registration
  • Sign up to TISC
  • Records supplier accreditation, compliance and registration with bodies such as Sedex or the Open Supply Hub or the Living Wage Foundation
  • Shows if the supplier has a Carbon Reduction Plan and action plan for Modern Day Slavery

UCL is engaged with suppliers to promote greater alignment with UCL’s values.

Staff Engagement Actions

In 2022/23, UCL maintained its commitment to staff development with the ongoing provision of the 'Change Possible' course. The enhanced the course content from last year's update included a dedicated section on responsible procurement, emphasising its stance against modern day slavery and exploitation in UCL's purchasing practices. Compliance rates for end FY22/23 were 86% of eligible staff. Line managers are working with staff to improve the compliance and are being encouraged to ensure all staff complete mandatory training.

This specialised training course is a requisite for all new UCL staff, to be completed within six weeks of joining, and triennial completion remains mandatory for all existing employees.

As UCL progresses in FY23/24, it remains dedicated to the continual monitoring, improvement, and transparent reporting of course completion rates. UCL’s goal is to ensure that staff are well-informed and equipped to champion ethical and responsible procurement practices throughout the organisation.

Supplier Engagement Actions

Following a review of the supplier base via TISC, 672 of UCL’s suppliers are required to comply with the Modern Slavery Act 2015; 589 have provided the relevant statements. Of the 83 suppliers identified as potentially being required to comply but not having provided a statement, 63 were confirmed as not being required to submit a statement or were no longer active suppliers with UCL.  UCL is working actively with the remaining 20 (3%) suppliers to ensure compliance in 2023-24. It continues to encourage SME suppliers to complete action plans.

Goals and KPIs for FY23/24

UCL’s goals for FY23/24 include:

Building on the progress made so far and signalling some of planned areas of focus in this Statement.


UCL’s Supply Chain Policy is reviewed annually (last reviewed December 2022) and its procedural outline on this can be found on the Commercial & Procurement Services’ website. Within the Commercial & Procurement Services department, this year it utilised standardised templates for competitive sourcing, incorporating additional governance measures for procurements that carry medium and high risks related to Modern Day Slavery.

Furthermore, as part of UCL’s continuous supplier management efforts, it is incorporating modern day slavery and sustainability topics into ongoing practices. It remains actively engaged with both suppliers and HE Purchasing Consortia to identify and champion best practices in these areas.


UCL will continue to assess and monitor the risks of modern day slavery at every stage of a procurement. Through ongoing supplier engagement, it reviews practices within the supply chain.

Due diligence

UCL has deployed revised terms and conditions for low spend goods/services and has been monitoring modern day slavery risks and compliance via the tools set out above.

UCL continues to engage in dialogue with and monitor accreditation and certification bodies for best practice and promote collaboration with suppliers to identify and report any incidences of modern day slavery.

Enhanced supply chain mapping

Category management plans continue to be deployed with a particular focus on high and medium risk areas. These are used to examine other supply chain tiers.

In the procurement and deployment of its new sustainability tools UCL aims to streamline its compliance checks and reporting processes related to modern day slavery and risk assessments.

Key Performance Indicators

Staff training

  • Target of 95% completion rate for mandatory training modules for eligible staff

Supplier audits

  • Complete and review 20 supplier audits as part of ongoing supplier relationship management programme

Supplier modern slavery statement compliance

  • Maintain transparency of supply chain compliance via the TISCreport.org supplier dashboard
  • Investigate all instances of reported non-compliance


Report and investigate 100% of whistleblowing cases made to UCL.

  • Monitor and review the outcomes of whistleblowing cases reported by our partners.

UCL will continue to work with TISCreport to publish its Modern Day Slavery Statement and review its supplier base. The outputs of this activity are publicly available.


Appendix 1: Companies within University College London control

Below is a list of companies operating within University College London (“UCL”) control.

Company NameCountryRegistered Number

Signed by:

Dr Michael Spence, President, and Provost University College London
Dated: 23/02/24