UCL Slavery and Trafficking Statement


This statement is made pursuant to Section 54 part 6 of the Modern Slavery Act 2015 and sets out the steps that UCL (University College London) has taken to ensure that slavery and human trafficking are not taking place in our supply chains or in any part of our business.

Our organisation’s structure

UCL is London’s Global University whose core business is teaching and research, comprising 11 academic faculties supported by professional services divisions. Located principally in the Bloomsbury quarter of London, UCL has approximately 36,000 students and 12,000 staff.  The university is supported by a centralised procurement and contracting function with transactional purchasing devolved to individual departments.

Our policy on slavery and human trafficking

UCL is committed to acquiring goods and services for its use without causing harm to others.  In doing so, UCL is committed to supporting the UK Government’s approach to implementing the UN Guiding Principles on Business and Human Rights.

In implementing this approach UCL supports the Base Code of the Ethical Trading Initiative:

  • Employment is freely chosen
  • Freedom of association and the right to collective bargaining are respected
  • Working conditions are safe and hygienic
  • Child labour shall not  be used
  • Living wages are paid
  • Working hours are not excessive
  • No discrimination is practised
  • Regular employment is provided
  • No harsh or inhumane treatment is allowed

Our Supply Chains

UCL’s supply chains are managed under four “super-categories”:

  • Laboratory and workshop consumables and equipment
  • ICT equipment and services
  • Estates goods and services
  • Professional services

Our assessment at this time is that the principal areas which carry material risks are office supplies, laboratory consumables, ICT and AV equipment, and some estates services, such as cleaning, catering and security services.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Preliminary work is under way on an Anti-Slavery and Human Trafficking Policy which will reflect our commitment to acting ethically and with integrity in all our business relationships, and the implementation and enforcement of effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chains.

What we are doing now

UCL’s procurements follow one of two pathways: collaborative, through regional HE purchasing consortia, or in-house tendering and contracting.  UCL actively engages with its purchasing consortia to support the inclusion of ethical sustainability, including addressing slavery and human trafficking, in their procurement programmes.

UCL’s in-house tendering and contracting processes include some prequalification clauses which address the London Living Wage, and our major soft service contracts already include this requirement. Our standard terms and conditions have clauses covering modern slavery and human trafficking.

We use the DEFRA Prioritisation tool and the Responsible Procurement Code as tools to assess the risks and to monitor progress with mitigation.

What we are going to do in the Future

As part of this reporting exercise in this and the coming years, UCL expresses its commitment to better understand its supply chains and working towards greater transparency and responsibility towards people working on them.

For contracts that we have awarded we will identify those supply chains which represent a medium to high risk of modern slavery, human trafficking, forced and bonded labour, and labour rights violations. We will record this assessment of risk using the DEFRA Prioritisation tool and the Responsible Procurement Code, and working with our suppliers will more closely monitor the supply chains that have been identified as a potential risk and take appropriate action as necessary.  We envisage identifying such action in collaboration with our purchasing consortium partners and with appropriate NGOs.

Rex Knight
Vice Provost, Operations
July 2016