This year has been about strengthening our current processes whilst gaining a better understanding of our highest risk categories. We have written additional standard questions for our tender process and a MDS impact analyse has been utilised by procurement staff on major tenders to identify potential risks early. We will continue to embed both into our normal ways of working.
A risk prioritisation exercise has been conducted, to assess social risks within spend categories, and we have investigated our highest risk categories. We have focused particularly on IT hardware, reviewing where UCL follows Electronics Watch contract conditions.
Supplier engagement has resulted in 900+ suppliers being signed up to the NETpositive supplier tool. Critically we identified suppliers who stated not having awareness of Modern Day Slavery, and saw this number reduce through targeted engagement. We will continue to encourage our key suppliers to use this tool.
We have promoted external online training resources for staff, to raise awareness and understanding of slavery
This year we have followed HEPA good practice guidance on writing the MDS update to ensure that the statement provides the required insight.
The purpose of this document is to provide an update on UCL's commitment to understand our supply chains and identify, prevent and mitigate Modern Day Slavery across them. In 2016 UCL published its first Modern Day Slavery Statement, followed by an update in 2017. This is our update for the financial year ending 31st July 2018. This work has primarily been through joint collaboration between UCL Procurement Services and the UCL Sustainability Team.
In our Slavery and Human Trafficking Statement we committed to the following initial actions:
- Implementation and enforcement of effective systems and controls to tackle slavery and human trafficking taking place in our supply chains.
- Commitment to better understand our supply chains and working towards greater transparency and responsibility towards people working in them.
- Monitor supply chains that have been identified as a potential risk and take appropriate action as necessary.
UCL is London's leading multidisciplinary university, with more than 13,000 staff and 40,000 students from over 150 different countries. Founded in 1826 in the heart of London, UCL was the first university in England to welcome students of any religion and the first to welcome women on equal terms with men. UCL is comprised of 11 Faculties. UCL is an exempt charity, in accordance with the Charities Act 2006 and receives funding from multiple sources to support activities and research.
UCL's main campus is in the heart of Bloomsbury, London, however we have buildings across the UK. UCL is building a new campus at Queen Elizabeth Olympic Park, to form part of a wider education and cultural quarter in the capital. As London's Global University, UCL is working with partners all over the world to achieve fair solutions to global challenges.
UCL procurement activities amount to £500M+ annual spend, procuring a wide range of goods and services to support the effective running of the university, across diverse supply chains including construction and estates, corporate services, information and communications technology and laboratory equipment and consumables. The goods and services are procured from suppliers across the world and our suppliers range from local SME’s through to large multi-national/global companies. In addition, a significant proportion of our expenditure is through procurement consortia.
UCL employs category focused procurement managers, who specialise in understanding the supply chains of these key spend areas. We conduct risk analysis to understand high risk categories and prioritise action for these supply chains.
Managing the risk of Modern Slavery
Policies and Governance
Modern Day Slavery is just one important issue from unethical and exploitative practices in workplaces and supply chains. A number of existing policies are in place to support fair working practices for our staff and suppliers, and ensure we buy ethically:
For People Working On Our Sites:
Our Human Resources Policies set out workplace rights at the University, including ensuring our new staff have the right to work in the UK.
Market Pay Policy agreed in partnership between UCL and the recognised trade unions, Unite (formerly Amicus), AUT and UNISON. This ensures UCL pay for UCL staff reflect the sector market.
Gender and Ethnicity Pay Gap Report looking at pay disparity across the organisation.
UCL Dignity at Work Statement 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.
For Our Supply Chains:
Procurement Strategy sets our principles and practices in the responsible acquisitions of goods and services.
Fairtrade Policy for UCL and UCLU (University College London Union) to support the principles, ethos and aspirations of Fairtrade and commit to using, selling and promoting Fairtrade products through all of our outlets and relevant activities.
Our last update detailed how we embedded our commitment to compliance with the Modern Slavery Act within our Sustainable Procurement Strategy and the due diligence role the Consortia we procure through play. Our tender process already ask suppliers if they are compliant with section 54 of the Act, and we exclude any suppliers that have been found guilty of committing modern slavery (in the last 5 years).
This year we have written additional standard questions for our tender process to investigate how suppliers are addressing Modern Day Slavery. These are aligned to best practice - the Government’s Transparency in Supply Chains Guidance and the Ethical Trading Initiative’s Guidance documents. Guidance notes have also been created, which will equip staff with the necessary information to be able to score responses to these questions.
Having developed the Impact Analyses approach, we are up-skilling procurement professionals in using the tool. The tool enables any social impacts such as exploitation, working conditions and slavery to be identified at the earliest stage, and the tender developed accordingly to address them.
- Continue to review tender questions for Modern Day Slavery, and will amend these on an ongoing basis.
- Provide the Impact Analysis Tool for all staff to use in their own procurement and purchasing decisions where appropriate.
To understand and manage risks within specific categories, we complete the Defra Prioritisation Exercise; this evaluates our categories against environmental risks identified from our Environmental Management System and social risks adapted from the ETI Base Code:
Not Paying Living Wage
Materials from conflict zones
Not promoting SMEs
Not promoting Fairtrade
Accessibility not considered
Unsafe/unhygienic working conditions
Excessive working hours
Irregular employment / gig economy
Modern day slavery
Freedom of association and the right to collective bargaining not respected
This risk analysis reviews our spend across categories, and calculates the potential for categories to have our selected environmental and social risks. The output is an understanding of which categories are high risk, and therefore should be targeted. By doing this exercise biannually, we are able to look at changes in risk.
This year, we conducted a prioritisation exercise including only socio-economic risks, against all our level one categories. This produced a risk score for all spend areas. See the table below:
|Category||Defra Social Risk|
|A Audio-Visual & Multimedia||5|
|H Janitorial (Cleaning)||5|
|S Stationery (Office Supplies)||4|
|U Health & Safety & Security||4|
|V Vehicles, Fleet Management||4|
|W Estates & Buildings||4|
|M Workshop & Maintenance||3|
|T Travel & Transport||3|
|B Library & Publications||2|
|R Professional & Bought-in Services||2|
CASE STUDY: Electronics Watch
We have mapped our IT hardware procurement to review how Electronic Watch’s contract conditions are being applied to our procurement of IT goods:
- UCL is a member of SUPC, who in March 2017 affiliated with Electronics Watch.
- UCL utilises LUPC’s national electronics framework agreement for Desktop & Notebook PCs, which includes model Electronics Watch contract clauses, for procurement of IT hardware.
- UCL utilises HEPCW Consortia Framework for Apple Products, where all suppliers have agreed to adopt Electronics Watch standard terms.
This year we have investigated our highest risk (scoring 5) categories and began reviewing high risk (scoring 4) categories:
A Audio-Visual & Multimedia
Reviewed the stock AV equipment purchased by UCL departments; all are EPEAT rated.
H Janitorial (Cleaning)
New contract tendered which incorporated paying London Living Wage to all contracted staff.
We reviewed our sourcing streams for ICT to ascertain if Electronics Watch contract conditions are applied (see case study).
We have audited our main catering provider to look at staff policies and procedures on slavery. This was facilitated through established sustainability contract management meetings.
We have tendered for a furniture supplier framework, and all supplier were required to answer enhanced questions on slavery in tender
- Continue to review level 5 and 4 risk categories and develop tailored actions for each.
Engagement, Training and Collaboration
In the last update, we explained how we are utilising the NETpositive tool to better understand our supply chains, and enable greater transparency and responsibility towards people working in them. Specifically we are able to ask suppliers questions on compliance with the Modern Slavery Act. There are now 900+ suppliers signed up.
We have conducted further engagement with those already signed up, which has included sending our own statement update to them. Specifically we engaged suppliers who stated not having awareness of Modern Day Slavery, and saw this number reduce from 71 suppliers to 64 (9.85% drop) as a result.
- Continue to focus on those suppliers that have significant business impact and risk.
As a community of over 13,000 staff and 40,000 students and a place of learning, we recognise our responsibility to raise awareness on this important issue, and to train some key staff specifically on Modern Day Slavery risks and best practice. We had previously provided Procurement staff training. Since then we have identified free eLearning courses which provide awareness on exploitation, human trafficking and slavery, and advertised these on our website:
- Protecting Human Rights in the Supply Chain eLearning by LUPC, APUC and the University of Greenwich
- Modern slavery eLearning by the Open University
Our work on Modern Day Slavery remains primarily driven by Procurement and Sustainability Team. As a research organisation, we wish to identify opportunities to utilise our academic and research expertise relevant to this work stream. We will also engage with other universities to share best practice.
As a member of Southern Universities Purchasing Consortia, we will compare their category risk management against UCL’s. We have become aware that SUPC have registered with the TISC report website, to list their statements, which we will also explore.
- Review central registries that host organisations Modern Slavery Statements and allow ours to be publically available. This will provide further transparency as per section 54. Additionally, this is in line with our corporate principle of being “Accessible and publicly engaged”.