Modern Slavery Statement 2018/19
The following statement is intended as an update to the actions The University of Sheffield has taken so far in our efforts to acknowledgement and adhere to section 54(1) part 6 of the Modern Slavery Act 2015. Furthermore, it will set out the University’s continued efforts to ensure that slavery and human trafficking are not taking place in our supply chain. This statement relates to the financial year 1st August 2018 to 31st July 2019.
As part of the Higher Education sector, the University of Sheffield recognises that it has a responsibility to take a robust approach to slavery and human trafficking. We are a member of the North East Universities Purchasing Consortium, The University Catering Organisation and The Energy Consortium, all of which are members of Procurement England Limited and are signed up to Procurement England Limited’s sustainable procurement policy, which can be found attached as a separate document at the end of this statement.
Procurement England Limited adheres to a joint Sustainable Procurement Policy, which includes undertaking risk assessments of products and services in supply chains and adopting mechanisms and indicators to monitor and review the performance of vendors and achieve continuous improvement. To see the full policy, please see the document in the downloads box.
2. The University’s Structure, Business and Supply Chains
With 29,000 students, who come from 150 different countries, and a turnover of £690m, The University of Sheffield is one of the biggest and most influential Universities in the U.K. We are a member of the Russell Group of Universities and our research has a global reputation. It influences policy, changes lives and helps us to understand the world so that we can make it better. We are an exempt charity under the terms of the Charities Act 2006 and incorporated by Royal Charter.
The University of Sheffield is dedicated to sector leading academic achievement across a broad range of disciplines. Our academic departments are grouped into five faculties:
- Arts and Humanities
- Medicine, Dentistry and Health
- Social Sciences
Our Professional Services are divided into the following structure:
- Corporate Services; including Human Resources and Health & Safety
- Academic Services; including Estates & Facilities, IT, Student Recruitment & Admissions and Research Services
- Finance and Commercial; consisting of Finance and Accommodation & Commercial Services
Overseas Representative Offices:
- City College, Thessaloniki, Greece
- Sheffield Advisory Services, Kuala Lumpur, Malaysia
- AMRC South Korea
We have reviewed the University’s Supply Chain in terms of the potential risk that it could include activities of Modern Slavery or Human Trafficking. Where expenditure is covered by purchasing consortia frameworks or formal contracts, the risk is minimised. By designating an area as higher risk, this does not mean we have evidence of non-compliant activity in our supply chain. It indicates where greater attention and focus will be placed in monitoring supplier relationships;
University Supply Chain expenditure higher risk areas of Modern Slavery or Human Trafficking:
- Estates Goods and Services
- IT equipment
- Facilities Management (Including Maintenance)
- Laboratory Supplies
- Office Supplies
- Overseas Student Recruitment
- Library & Student Support Services
- Professional Services (eg Professional External Advisory Services in relation to HR, Legal, Marketing, Finance and Health & Safety issues)
- Grant Funded specialist/high value Equipment
3. Our Policies and Due Diligence in Relation to Slavery and Human Trafficking
The University of Sheffield operates the following policies that describe its approach to the identification of modern slavery risks and the steps we are taking to prevent slavery and human trafficking in our operations:
Whistleblowing Policy: The organisation encourages all its customers, staff and business partners to report any concerns related to the direct activities of the organisation, or those of its supply chain. This includes any circumstances that may increase the risk of slavery or human trafficking.
Supplier Code of Conduct: The organisation remains committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
Agency Workers Policy: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
We are committed to running our organisation in an ethical and sustainable manner and support the Base Code of the Ethical Trading Initiative. We are involved with Electronics Watch and are currently reviewing the possibility of signing up to their Terms & Conditions, which would put us ahead of our peers in the HE sector and help us in our quest to manage the risk of Modern Slavery and Human Trafficking within our IT supply chain.
We are currently finalising a Procurement Strategy, which will include a section on ethical procurement, referencing the Modern Slavery & Human Trafficking Act, as well as a separate section on sustainable procurement. We aim to publish this on the procurement section of our website by April 2019.
Finally, the University has recently published its own Sustainability Strategy, which can be found here.
Our sustainable procurement policy (a sub section within the Procurement Strategy) will be closely linked to this.
4. Actions for 2018 / 19
In addition to the actions we’ve already taken to adhere to the Modern Slavery and Human Trafficking Act, the University of Sheffield aims to:
- Continue to improve our training and awareness of the Act within procurement and the wider organisation
- Continue to discuss to Act with our suppliers, and ensure they adopt responsibility through the clause inserted into our standard Terms & Conditions
- Procure through NEUPC, TUCO and TEC frameworks as much as possible, thereby supporting PEL and their sustainable procurement policy
- We have recently published our own Sustainability Policy (available online), and there will soon be an updated Procurement Strategy (available online by April 2019), which will include a section on the Modern Slavery and Human Trafficking Act
- We are exploring a potential area of risk within our overseas recruitment of students, which has traditionally been relatively high use and high spend. If contracting (and therefore putting legal responsibility onto the suppliers to adhere to our terms & conditions) or building a framework with consortium support are not options for us, then we will investigate alternatives that will ensure this risk is minimised.
5. Training and Measurement
Following the introduction of the Modern Slavery and Human Trafficking Act in 2016, our team held several internal discussions, training and awareness sessions. In early 2018, every member of the team then completed an e-learning module from the London Universities Purchasing Consortium called ‘Modern Slavery and Protecting Human Rights in the Supply Chain’.
As part of our new Procurement Strategy, we will be implementing a new training programme to be completed throughout 2019. This will include training materials from the UK Training Delivery Group and the Anti-Slavery Partnership Toolkit, which has been developed by Nottingham University in partnership with the Office of the Independent Anti-Slavery Commissioner.
Furthermore, the above training will become standard for all new starters into our procurement team. The intention is that this updated training programme will then cascade out to other members of staff with purchasing authority across faculties and professional service areas within the University.
6. Review and Approval
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is reviewed annually. It was approved and signed by the President and Vice-Chancellor on 31st January 2019.
Professor Koen Lamberts
President and Vice-Chancellor
For and on behalf of the University of Sheffield