Modern Day Slavery Statement Update 2023-24

This is an update on the work UCL has undertaken in 2023-24, 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 9^th December 2024 and signed by the President and Provost of University College London company number RC000631 (“UCL”) on behalf of UCL on 19^th December 2024.

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

Introduction

UCL is steadfast in its mission to prevent and eradicate any instances of modern day slavery and human trafficking within its supply chain. Upholding human rights continues to be a central pillar of UCL’s operations, reflecting its firm commitment to ethical practices. This Statement highlights UCL’s unwavering dedication to transparency, integrity in business practices, and the protection of human rights. As a globally recognised institution, UCL understands the importance of aligning its operations with its core values.

Since first publishing its Modern Day Slavery Statement in 2016, UCL has issued annual updates.  Led by Commercial & Procurement Services and Sustainable UCL, this work reflects UCL’s ongoing efforts to address modern day slavery risks within its supply chain.

Key commitments include:

• Continually deepening its understanding of supply chains to enhance transparency and accountability for the welfare of workers.
• Building awareness of how to recognise and report suspected modern day slavery incidents.
• Proactively monitoring supply chains identified as potential risks, taking decisive action as required.
• Establishing and employing effectual systems to combat slavery and human trafficking within UCL’s procurement network.
• Delivering tailored staff training to ensure awareness of modern day slavery risks and their identification.

UCL’s Structure, Business, and Supply Chains

UCL is a multidisciplinary university, home to 16,000 staff and 50,000 students, representing a global community from over 150 countries.

Founded in 1826 in central London, UCL was pioneering in its admission of students regardless of religion and its promotion of gender equality in education.

UCL’s research and operations are driven by its Sustainability Strategy and the United Nations Sustainable Development Goals (UN SDGs):

• UCL consists of 11 Faculties
• As an exempt charity under the Charities Act 2011, UCL receives funding from a variety of sources to support its extensive academic and research activities.

UCL Consultants Limited, a wholly owned subsidiary of UCL (company number 03332258), is led by its Managing Director and governed by a Board of Directors, with meetings held quarterly and attended by a representative from UCL’s University Management Committee (UMC).

Our business

UCL’s mission as a diverse and dynamic intellectual community continues to drive its engagement with global issues and its commitment to fostering positive change.  UCL aims to remain a leading force in critical thinking, education, and research, striving to seamlessly integrate innovation and entrepreneurship for the betterment of society.

Through its Sustainability Strategy, UCL is positioned to influence sustainable actions both locally and globally. The Sustainability Strategy (pdf) for the years 2019 to 2024, underpinned by the UN SDGs, was developed with input from 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 approving 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.

Locations

• UCL’s main campus is situated in Bloomsbury, London, with buildings located across the UK.
• UCL's newly developed campus at Queen Elizabeth Olympic Park, first opened in November 2022
• UCL collaborates with partners on a global scale.

UCL’s Supply Chain

In FY23/24, UCL spent approximately £1bn (including VAT) procuring a wide range of goods and services across the globe.  UCL’s supply chain spans third-party suppliers providing products and services that support its educational, research, and operational needs.

Sustainability is a key principle in UCL’s procurement approach, shaping its financial management, reputation, and Corporate Social Responsibility (CSR) efforts.  UCL works closely with suppliers who share its values, fostering innovation and maintaining competitiveness through its Commercial & Procurement Services function.

UCL’s supply chain supports diverse requirements, 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

UCL’s suppliers range from local small businesses to large multinational corporations. As part of its due diligence, UCL systematically documents supplier head office locations and policies, especially concerning modern day slavery and human trafficking.  This due diligence work includes risk assessments of supplier categories to prioritise action where potential exploitation risks may exist. UCL collaborates with its largest and most strategic suppliers to thoroughly map and scrutinise their supply chains, underscoring its commitment to sustainability and ethical procurement.

Modern Day Slavery and Human Trafficking Policies

Modern day slavery is a pressing issue for UCL.  UCL requires its suppliers to uphold policies that ensure fair working conditions and ethical procurement, outlined below. Where UCL Consultants Ltd’s policies differ from UCL’s they are highlighted below. 

Policies and Governance

Summary of Governance

UCL upholds a deep-rooted commitment to its environmental responsibilities, reflected in its ongoing efforts to minimise its environmental footprint. The Provost and Council provide strategic direction and resources through UMC to drive these initiatives forward.

Each year, the UMC reviews UCL’s sustainability report to assess progress and areas for improvement.

The Sustainability Committee continues to oversee the development and management of UCL’s approach to Sustainability and the Sustainable Finance Framework. This committee acts as a collaborative platform for key stakeholders, including students, to meet, review, and approve critical sustainability goals, propose targets, and monitor overall performance.

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

Goals and Key Performance Indicators (KPIs)

UCL’s approach to mitigating modern day slavery risks is reinforced through specific goals and Key Performance Indicators (KPIs). Building on the recommendations from KPMG's audit of its policies, UCL continues to track progress against an action plan co-developed to bolster policies and procedures related to modern day slavery across its supply chain.

The following actions continue to be developed and managed:

• Enhanced due diligence of low-value goods and services
• Strengthened policies in key risk areas
• Expanded supply chain mapping to better understand potential risks
• Targeted Key Performance Indicators to track progress
• Processes to support the Supply Chain Policy
• Increased collaboration with contracted suppliers to promote ethical practices
• Enhanced staff training programmes focused on modern day slavery awareness

UCL has also advanced its transparency efforts by sharing its Statement via the UK Government's Modern Day Slavery Statement Registry. It continues to work closely with the Transparency in Supply Chain (TISC) platform to assess supplier compliance. UCL encourages its supply chain partners to register on the TISC platform, actively promoting best practices.

Reporting and Assessing the Risk of Modern Day Slavery (Actions Taken in 2023/24)

Living Wage

UCL maintains its accreditation with the Living Wage Foundation, actively promoting the adoption of living wage practices across its supply chain. As part of this accreditation, UCL conducts annual audits of suppliers to ensure pay parity for staff regularly deployed to UCL sites. In addition, UCL’s procurement terms and conditions for low-value goods and services encourage the payment of in-country living wages. 

Reporting

UCL demonstrates its commitment to combating modern day slavery by registering its statement with both the UK Government’s Modern Slavery Statement Registry and TISCreport. In FY23/24, UCL assessed compliance within its supply chain via TISCreport.org, engaging suppliers to join this initiative where appropriate.

Within UCL’s supplier network of over 7,000 suppliers, TISC identified:

• 625 suppliers who were confirmed as compliant with modern day slavery legislation, accounting for £190m of UCL's third-party expenditure during FY23/24.
• 24 suppliers with a spend of £4.1m in 23/24 who were non-compliant.  An action plan to drive compliance with or stop working with these suppliers will be rolled-out in 24/25.

The review of suppliers covered by TISC revealed that a number of high spend suppliers to UCL were not included in TISC’s analysis.  To provide further assurance that UCL’s supply chain is compliant with modern day slavery legislative requirements, further desktop checks were undertaken on 27 major suppliers with a total annual spend of £213m (ex. VAT).  All 27 suppliers were compliant.

Combining the outcomes of TISC-compliant suppliers, and the additional checks on other major suppliers, assurance on compliance with modern day slavery legislation has been confirmed for 652 suppliers, covering £403m ex. VAT (46% of 23/24 spend).

UCL is a member of the Open Supply Hub (formerly the Open Apparel Registry), sharing factory-level information on garment-related suppliers to enhance transparency in supply chain practices. The Hub offers comprehensive factory-level information on manufacturing plants worldwide, with a primary focus on garment-related products, such as uniforms.

Supplier consolidation

UCL remains focused on managing its supply chain effectively by continuously assessing the risk profiles of suppliers with lower-value spend. It is taking steps to consolidate its supplier base via Preferred Supplier Lists, ensuring that contracted suppliers adhere to UCL’s standard contract terms, including modern day slavery reporting requirements.

Assessment of risk

UCL has conducted an in-depth risk assessment of its procurement categories, using UK Government’s modern slavery procurement guidance and data from various sources, such as the International Labour Organization’s Global Estimates of Modern Slavery (GEM) (pdf) and the US Department of Labor's 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
• Investments’ management companies

Managing the Risk of Modern Day Slavery (Actions Taken 2023/24)

UCL has continued to embed modern day slavery mitigation into its procurement processes. This includes maintaining robust terms and conditions that require suppliers to comply with modern slavery legislation and UCL’s own policies. Regular audits and the ongoing review of action plans are critical components of UCL’s strategy to manage risk.

For its core facilities maintenance contracts, covering services such as catering, cleaning, and waste collection, UCL works with third-party companies employing diverse teams, including both UK-based and international staff. UCL ensures that suppliers maintain strong ethical standards throughout their supply chains, mandating immediate reporting of any breaches.

To address Modern Day Slavery risks comprehensively, UCL has integrated measures directly into each phase of its procurement activities. UCL requires ongoing 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.

In FY23/24, UCL continued its efforts to address modern slavery and human trafficking risks in its supply chain. Building on goals from UCL’s 22/23 Statement, UCL made progress in two key areas.

Supplier Audit Programme Development

UCL started developing a framework for conducting supplier desk audits, focusing on assessing compliance with modern slavery regulations and ethical labour practices for key high-risk suppliers. This included: 

• Outlining an approach to identify suppliers for potential auditing
• Drafting initial audit protocols and assessment criteria
• Establishing preliminary internal processes for desk-based audits
• Beginning communication with suppliers about our audit intentions

20 major suppliers were involved in a pilot desk audit programme which assessed them on their compliance with modern day slavery legislation, alongside assessments on other measures of sustainability.  16 (80%) suppliers responded, all reporting compliance with the legislation.

Following its successful piloting in 23/24, this approach will be fully implemented in 24/25.

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 Computacenter, a leading independent technology and services provider, trusted by large corporate and public sector organisations. They are a responsible business that believes in winning together for their people and our planet. Computacenter’s “Global recognition tool ‘Bravo!’ helps them to foster a high-performance culture through recognising and rewarding one another’s great performance. It has been a crucial component of employee engagement since March 2020, and Computacenter is proud that the scheme was shortlisted in the Employee Benefits Awards 2022 for ‘Best motivation or recognition scheme’”.

Catering

Within catering, UCL continues to procure both front-of-house (retail) and back-of-house (events and hospitality) food and services. We remain committed to working closely with our catering provider to mitigate the risk of forced labour or human trafficking within our supply chain. Additionally, we focus on high-risk products, including palm oil, cocoa, and sugar cane, and prioritize ethical sourcing in alignment with UCL’s Healthy & Sustainable Food Policy. Certifications such as the Marine Stewardship Council (MSC) for fish, the Roundtable on Sustainable Palm Oil (RSPO) for palm oil, and ProTerra for soy are part of this effort to ensure fair labour practices are maintained.

For FY23/24, our catering provider employs approximately 182 staff members on-site and places a strong emphasis on sourcing fresh, local, and seasonal goods wherever feasible. Most Tier 1 suppliers are based in the UK, while some products are sourced from the EU and other parts of the world. The catering provider actively works towards achieving full compliance within its supply chain and supports UCL’s extended suppliers in aligning with the Modern Slavery Act 2015.

As part of their Modern Slavery compliance program, UC’s catering provider requires all business partners to provide training to their staff, suppliers, and providers. A supply chain compliance system is in place, supported by the use of the Authenticate database, which ensures that suppliers upload their own Modern Slavery policies and commit to adhering to the provider's standards.

To date, no cases of modern slavery have been reported within the catering supply chain. UCL’s supplier remains vigilant, maintaining key performance indicators (KPIs) to track progress in this area, including mandatory Modern Slavery training for all employees and requiring suppliers to share their Modern Slavery policies. Compliance with these practices ensures that the catering provider continues to meet UCL’s expectations in supporting ethical and responsible supply chain management.

Cleaning & Non-Hazardous Waste Collection

UCL’s primary cleaning and waste service provider, with 891 staff on-site, continues to implement measures to combat modern day slavery across its operations and supply chains. In FY23/24, these efforts earned recognition from the Unseen Business Awards, with senior leadership within the organisation being awarded the Individual Impact Award 2023. 

The provider also developed and leads an anti-slavery initiative, supported by both the Cabinet Office and the Home Office. As part of this, a modern day slavery toolkit was launched in 2023 to guide organisations in identifying and eradicating modern slavery within their supply chains. This toolkit is now being widely used as a resource to promote ethical practices.

In addition, the provider has continued its comprehensive training and compliance programs. Responsible Business training is mandatory for all staff, and modern slavery risk training was initially delivered in 2021. In FY23/24, a new front-line training pack was developed and will be introduced in FY24/25, equipping staff with the knowledge to recognise and report any signs of modern slavery responsibly and safely.

The provider is also committed to ensuring compliance across its supply chain, which includes over 7,000 suppliers. All its suppliers are required to adhere to a strict code of conduct, and their compliance is reinforced through contractual obligations. In FY23/24, 97.1% of staff completed the mandatory modern slavery training. This approach reflects the provider’s continued dedication to fostering a responsible and ethical business environment, ensuring there are no opportunities for modern slavery within its supply chain.

Construction

UCL completed a large number of small to medium sized construction projects in 23/24 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.

Security

The provision of onsite security services continues to represent a medium-level risk in terms of labour and rights violations. UCL remains committed to working closely with its supplier to ensure adherence to best practices. As of the fiscal year 2023/2024, approximately 234 security staff were deployed at its locations.

UCL’s security supplier maintains stringent policies to ensure that its supply chain upholds necessary standards.  They continue to work exclusively with subcontractors who demonstrate rigorous recruitment procedures and compliance with relevant laws and regulations. The supplier also offers ongoing internal training courses and employee toolbox talks to equip managers, supervisors, team leaders, and HR professionals with the skills needed to identify signs of modern day slavery.

As part of its commitment to supporting social causes, the supplier has continued its partnership with Unseen UK, a UK-based charity that provides safehouses and community support for victims of trafficking and modern day slavery. This charity operates a UK-wide, free, 24/7 Modern Slavery & Exploitation Helpline for victims, the public, frontline workers, and law enforcement. Through this partnership, the supplier actively participates in raising awareness and supporting initiatives aimed at eradicating modern slavery.

The supplier continues to apply rigorous recruitment techniques, which include:

• Rigorous Interview Procedures: All applicants undergo comprehensive interviews to ensure they personally complete their registration forms.
• Approved Interview Locations: All job interviews are conducted exclusively at approved locations.
• Preventing Unauthorised Agents: Procedures 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 involving recruitment agents to management and law enforcement agencies where necessary.

In addition to these recruitment measures, ongoing monitoring of supplier staff post-employment continues to ensure that no signs of modern day slavery are present. Supervisors are trained to monitor key indicators, such as:

• Physical Appearance: Monitoring employees for signs of abuse or malnutrition, ensuring their physical well-being.
• Personal Effects and Documentation: Reviewing employees' personal documents to verify their identity and freedom of movement.
• Freedom of Movement: Ensuring that staff have the freedom to move independently without third-party control.
• Third-Party Influence: Ensuring that no external parties are coercing or exploiting employees.

The recruitment stage remains a key area of focus, as it is where workers are most vulnerable to exploitation, particularly when third-party labour recruiters are involved. The supplier takes special care in these situations, especially when recruiting migrant workers, by:

• Working exclusively with reputable, registered labour and service providers.
• Establishing clear service level agreements (SLAs) with all labour providers.
• Conducting regular checks on labour and service providers’ management systems, including verifying right to work documents, contracts, and wage practices.
• Holding regular conversations with agency workers and service provider staff to ensure their fair treatment.

Through these measures, UCL and its supplier continue to uphold their commitment to combating modern day slavery in their operations and supply chains.

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.

Travel

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 2023/2024 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 noted 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. The supplier continues to uphold the importance of improved awareness, considering it one of the most effective methods to reduce the risk of modern slavery. With the active participation of both its employees and suppliers, they aim to ensure that there are no opportunities for forced labour to be concealed within their organisation or supply chain.

In addition to complying with the requirements of the Modern Slavery Act 2015, the supplier endorses the tenets of the United Nations Global Compact Principles, the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, and the Ethical Trading Initiative ‘Base Code’. This includes ensuring that employment is freely chosen, freedom of association is respected, working conditions are safe and hygienic, child labour is not used, wages meet at least the minimum wage, working hours are not excessive, discrimination is not practised, regular employment is provided, and no harsh or inhumane treatment is tolerated.

The supplier continues to assess risks of non-compliance within their organisation and supply chain. Where risks are identified, an audit is conducted, including a focus on compliance with employment laws and other regulatory and sustainability criteria. Their supplier on-boarding process includes standard due diligence procedures to assess the suitability of vendors providing goods and services, ensuring their compliance with required standards. This process also captures confirmation that suppliers are committed to ensuring slavery and human trafficking do not occur within their own supply chains. Desktop audits are conducted as part of supply chain management to ensure that suppliers act as responsible partners in service delivery.

Tier 1 suppliers—those identified based on volume of spend and risk—are subject to biannual reviews to identify, understand, and mitigate risks associated with modern slavery. Additionally, all new applicants within the supplier's organisation are subject to identity and Right to Work checks, reference checks, and, where applicable, DBS checks before employment. The supplier ensures that most employees are directly employed, and salary payments are made directly to the individual.

Key performance indicators (KPIs) are used to measure the effectiveness of raising awareness of core policies and procedures related to the requirements of the Modern Slavery Act, as well as other actions designed to ensure that slavery and human trafficking do not take place in any of the supplier's business activities or supply chains.

UCL's Investments' Managers

For the first time, an evaluation of potential modern slavery risks within the operations and supply chains of UCL’s investments’ management companies was conducted.  This assessment focused on:

• Compliance with the Modern Slavery Act 2015
• Examination of supply chain practices
• Analysis of transparency scores from TISCreport, an advocacy organisation promoting transparency in UK-registered companies

Based on an initial assessment, UCL did not identify any immediate critical concerns that would warrant terminating relationships with these companies.  It is recognised that addressing modern slavery risks is an ongoing process that requires continuous monitoring and engagement.  Recommendations from the findings include encouraging ongoing transparency and regular reporting on supply chain practices.

This dual approach of developing UCL’s audit capabilities and assessing key investors demonstrates its commitment to continually improving UCL’s efforts to address modern slavery risks throughout its extended network of business relationships.

Due diligence

Enhanced Questions

When procuring goods or services in high-risk categories, UCL has consistently applied industry-leading practices. This includes the use of enhanced due diligence questions, informed by the UK Government’s Transparency in Supply Chain Guidance. These questions are tailored to uncover potential modern day slavery risks and ensure that suppliers meet UCL's ethical standards.

Supplier management

UCL maintains comprehensive records of its contracted suppliers, ensuring it tracks key compliance data, such as:

• Modern Day Slavery Statement compliance and registration
• Participation in the Transparency in Supply Chains (TISC) initiative
• Supplier accreditation, compliance, and registration with ethical bodies such as Sedex or the Open Supply Hub or the Living Wage Foundation
• Availability of supplier Carbon Reduction Plans and Modern Day Slavery action plans

Through ongoing engagement, UCL actively encourages its suppliers to align more closely with its values, promoting ethical and sustainable practices throughout the supply chain.

Staff Engagement Actions

In FY23/24, UCL maintained its commitment to staff development by continuing to deliver its 'Change Possible' course. Following on from previous years updates the course includes an expanded section dedicated to responsible procurement, focusing on the fight against modern day slavery and unethical practices within supply chains. We actively seek input from our staff to enhance our modern slavery training. Through a structured feedback process, we encourage all participants to share their insights, suggest improvements, and identify any gaps in the current curriculum. This collaborative approach ensures our training remains relevant, comprehensive, and aligned with the evolving challenges in combating modern day slavery.

As of the end of FY23/24, a further 6,132 people had completed the training, and efforts are ongoing to improve compliance through support from line managers, who are encouraged to ensure full completion across their teams. This course remains mandatory for all new employees, who must complete it within six weeks of starting at UCL, and for existing staff, it must be retaken every three years.

As UCL progresses in FY24/25, it remains focused on tracking and improving compliance rates, with a particular emphasis on ensuring that staff are fully equipped to uphold UCL's ethical procurement standards.

Supplier Engagement Actions

Following a detailed review of its supplier base using the TISCreport.org platform, UCL identified 625 suppliers who complied with the Modern Slavery Act 2015.
Further, the TISC report process identified 24 suppliers who were non-compliant with the legislation.  UCL is actively engaging with these suppliers to ensure they achieve compliance by the end of FY24/25 or to cease working with them.  Additionally, UCL continues to encourage small and medium-sized enterprises (SMEs) in its supply chain to complete modern day slavery action relevant action plans.

Further compliance checks were undertaken for other major suppliers not covered by the TISC report process.

Goals and KPIs for FY24/25

UCL’s objectives for the 24/25 financial year include building on past successes while identifying new areas of focus for continuous improvement in addressing modern day slavery risks. Key goals and actions include:

Policies

UCL’s Supply Chain Policy is reviewed regularly with the most recent review conducted in December 2022. Details of this policy can be found on UCL’s Commercial & Procurement Services website.

Within the department, UCL has standardised its competitive sourcing templates and incorporated additional governance measures for procurements identified as carrying medium to high risks in relation to modern day slavery. As part of its ongoing supplier management efforts, UCL continues to integrate modern day slavery and sustainability considerations into its procurement processes. It also collaborates closely with suppliers and the Higher Education (HE) Purchasing Consortia to champion best practices in these areas.

UCL's Commercial & Procurement team, in collaboration with key stakeholders across the University are developing a comprehensive Supplier Code of Conduct. This Code of Conduct will be integrated into all supplier relationships and will explicitly articulate UCL’s expectations regarding modern slavery prevention. Central to this code is UCL’s unwavering zero-tolerance stance on modern slavery and human trafficking. The implementation of this Supplier Code of Conduct serves multiple purposes: 

1. It clearly communicates UCL’s ethical standards and expectations to all suppliers
2. It provides a framework for assessing and monitoring supplier compliance
3. It strengthens due diligence processes in supply chain management

The goal is to engage all active suppliers in this initiative, fostering a shared commitment to combating modern slavery. By doing so, UCL aims to enhance transparency and accountability throughout its supply chain, thereby reinforcing safeguards against modern slavery practices. This approach not only aligns with UCL’s institutional values but also demonstrates its proactive attitude in addressing potential risks within its extended business network.

While UCL’s Supply Chain Policy outlines UCL's internal strategic approach and principles for managing supply chain activities, the Supplier Code of Conduct serves as an external-facing document that explicitly communicates our ethical expectations to our suppliers. The Supply Chain Policy primarily guides UCL staff in their procurement decisions and processes, ensuring compliance with institutional regulations. In contrast, the Supplier Code of Conduct is a targeted instrument that focuses on setting clear standards for supplier behaviour, particularly in areas such as modern slavery prevention, ethical labour practices, and sustainability. This Code goes beyond internal governance to actively engage suppliers in upholding UCL's values and commitments. By implementing both documents, a comprehensive framework is established that not only directs internal practices but also extends UCL’s ethical standards throughout the supply chain, fostering a shared responsibility for social and environmental stewardship.

Risk

UCL remains committed to regularly assessing and monitoring the risks of modern day slavery at each stage of the procurement process. Through ongoing supplier engagement, UCL maintains and improves its understanding of risks across its supply chain.

Due diligence

UCL will work to review and revise its terms and conditions for low-spend goods and services, embedding modern day slavery risk assessments and compliance checks throughout its procurement activities. UCL also continues to engage with accreditation and certification bodies, promoting best practices and encouraging greater collaboration with suppliers to identify and address any instances of modern day slavery.

Enhanced supply chain mapping

UCL's category management plans are continuously updated, with a particular focus on high and medium-risk areas. In 24/25, category planning work will focus on work with suppliers to reduce Modern Day Slavery risks.

By maintaining this proactive and thorough approach, UCL aims to enhance its understanding of potential vulnerabilities throughout its supply chain, including those that may be less immediately visible.

As UCL integrates its new sustainability tools, the aim is to streamline compliance checks and reporting processes related to modern day slavery, making it easier to monitor risk and ensure timely interventions where needed.

Key Performance Indicators

UCL has set ambitious targets for FY24/25, focusing on key areas that contribute to ethical procurement and risk management.  Further work will be undertaken to embed the following KPIs within UCLC, building on its modern day slavery risk in its risk register:

Staff training

• Aim for a 95% completion rate of mandatory training modules for all eligible staff.

Supplier audits

• Utilise findings from supplier audits to drive tailored interventions with key and high risk suppliers, providing guidance and support for any identified gaps. Further, to incorporate these findings into ongoing supplier relationship management work.

Supplier Code of Conduct

Delivery of a new supplier code of conduct, focusing on: 

• Obtaining acknowledgment of the new code of conduct from Tier 1 suppliers
• Integration into procurement processes 
• Monitoring supplier adherence and feedback

Supplier modern slavery statement compliance

• Continue to ensure transparency within the supply chain using the TISCreport.org dashboard.
• Further assurance work on other major suppliers.
• Investigate any instances of reported non-compliance to ensure they are addressed promptly.

Whistleblowing

• Investigate and report on 100% of whistleblowing cases related to modern day slavery made to UCL.
• Monitor and evaluate the outcomes of whistleblowing cases reported by UCL’s partners.

Subsidiary companies

• A follow-up review of UCL’s subsidiary companies in the Appendix to continue to provide assurance that their activities form part of UCL’s supply chain.

UCL will continue its partnership with TISCreport to publish its Statement and provide updates on supplier compliance.  The results of these efforts will remain publicly accessible, ensuring full transparency and accountability.

Appendix 1: Companies within University College London control

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