Modern Slavery and Human Trafficking Statement

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, constitutes the University’s Modern Slavery and Human Trafficking Statement setting out the steps that University of Staffordshire has taken to combat modern slavery in our supply chain. We are committed to improving our practices to combat slavery and human trafficking.

Organisational structure

The University of Staffordshire’s core business is teaching and research in the Higher Education sector. It has a student population of approximately 10,000 in a wide range of subject areas, comprising academic schools and an Institute supported by professional services. In 2022/23 the University employed around 1,500 full-time equivalent (FTE) staff with a mix of full time and part time academic, administrative, technical and support staff.

The University had an annual turnover of £168 million (2022/23) of which c£60 million was spent on goods and services to support the running of the University. There has been a planned capital expenditure programme of c£53m over recent years to improve student facilities, with further developments planned in the coming years. The University has a centralised procurement and contracting function supporting procurement activity, with purchasing devolved down to individual schools and functions.

Our supply chains

Our supply chain includes many diverse suppliers, including providers of goods, services and works that directly support research and teaching activity, for example, student computer equipment, library services including books and online services, and suppliers of goods and services not directly related to these activities such as estate maintenance. Our requirements are from several categories which have been identified as ‘high risk’ in terms of the potential for slavery, servitude, forced and compulsory labour, and human trafficking.

These include, but are not limited, to:

• Hospitality and Catering
• Information Communication and Technology Equipment and Services (IT)
• Construction
• Clothing

Our initial targets in relation to Modern Slavery were as follows:

• To ensure our supply chain has been made aware of our policy regarding the Modern Slavery Act
• To promote best practice on approaches to Modern Slavery awareness throughout our supply chains
• To report on non-compliance identified within our supply chain and actions taken

Many of our suppliers in these higher-risk categories have committed to the Base Code of the Ethical Trading Initiative (ETI) and the UK Universities Purchasing Consortia are working to persuade the remaining suppliers in these categories to join them. The ETI Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice.

As a user of a variety of external framework contracts we continue to work closely with our locally based procurement consortium, the North Western Universities Purchasing Consortium (NWUPC), to manage risk through contract management processes.

Our policies and processes on slavery and human trafficking

We have embedded our commitment to compliance with the Modern Slavery Act within our Sustainable Procurement Policy. This policy provides guidance on how we deliver all our procurement activity. 

We have embedded consideration of the Modern Slavery Act in our procurement process from the Standard Selection Questionnaire and Invitation to Tender documents through to contract management. We request Modern Slavery statements for organisations over the £36 million threshold. For expenditure in high-risk categories, we ask how the company addresses compliance to the Modern Slavery Act as well as supplementary questions to ensure compliance.

We have embedded our commitment to all members of staff within University Policies that include Equality, Diversity, Health and Wellbeing and Bullying and Harassment.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. Any supplier or potential supplier who does not adhere to these values or is found not to be compliant will be suspended and removed from the University supplier list and will not be considered for future supply unless and until they are able to demonstrate full compliance with the requirements of the Modern Slavery Act.

Supplier engagement

In 2019 we launched a supplier development toolkit to support our suppliers on a range of sustainability issues, including Modern Slavery. The following details have been drawn from the tool and will be used to support and shape supplier development on Modern Slavery.

• All suppliers have received a free sustainability action planning tool
• All suppliers are asked to commit to actions on Modern Slavery and the take-up on these actions is monitored
• We review the evidence provided by suppliers on their Modern Slavery actions and commitments

Analysis of the 418 suppliers registered to the toolkit as suppliers to University of Staffordshire:

• 99% are aware of Modern Slavery
• 78% have made a public commitment to act against Modern Slavery
• 26% considered Modern Slavery an issue they need to address

Further analysis of those of our suppliers who have committed to action on Modern Slavery shows:

Develop a robust approach to removing Modern Slavery from their supply chains:

• Completed 33%
• In progress 40%
• Not started 25%

Provide Modern Slavery training for Staff:

• All staff receive training on annual basis 30%
• All staff receive training 30%
• All key staff receive training 22.5%
• No training provided 17.5%

Modern slavery risk analysis:

• Yes carried out 53%
• No but have plans to carry out analysis 24%
• No 6%
• Do not have significant supply chain 17%

We shall continue to increase awareness and support our suppliers to actively respond to the challenges of Modern Slavery.

Action completed and next steps

Action completed

Since we published our last Modern Slavery Statement, we have taken the following action:

• Ensured that Modern Slavery is considered at the start of every procurement project.
• Ensured that Modern Slavery is highlighted in the Invitation to Tender documents issued to bidders.
• The Head of Procurement has shared the GLAA ‘Horse Trading’ video and the updated HEPA training module ‘Guide to Modern Slavery’.
• All procurement staff have refreshed training on Modern Slavery.
• Identified major suppliers from expenditure classified as High Risk in line with H.E. Commodity Code analysis.

Next steps

The procurement team will use this baseline to develop deeper supplier engagement relating to Modern Slavery and Human Trafficking as follows:

• Increase use of the Supplier Engagement Toolkit for suppliers of goods and services identified as High Risk in line with HE definitions.
• Continue to develop Modern Slavery awareness amongst colleagues working with Procurement across the University.
• Increase the number of practical actions taken by our suppliers when responding to Modern Slavery.
• Continue to work with peers across the sector to share and learn on the best practices in tackling Modern Slavery.
• Consider the impact and recommendations of newly proposed BS25700 ‘Organisational Responses to Modern Slavery Guidance’.

Sally McGill
Chief Financial Officer
20 November 2023