Modern Slavery Act

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Keele University is committed to improving our practices to combat slavery and human trafficking.

Organisational structure

Keele University is a provider of teaching, research and enterprise in the higher education sector. Our mission is to make a difference in society by providing innovative, high quality education for students from all backgrounds and by undertaking world-leading research that transforms understanding and brings benefit to society, communities and individuals.

The Council is the supreme governing body of the University. It has a collective responsibility to promote the University’s well-being and, in particular, for the proper management and financial solvency of the institution. Major policy decisions, as well as corporate strategy, are also subject to its approval. The Council has a majority of lay members (neither employees nor students of the University), and includes among its members representatives of staff and students. The Vice-Chancellor has general responsibility to the Council for maintaining and promoting the efficiency and good order of the University.

The University Executive Committee (UEC) is the primary executive committee of the University and acts as an advisory committee to the Vice-Chancellor in leading the strategic direction of the University. UEC is chaired by the Vice Chancellor, Professor Trevor McMillan and comprises the Deans of the Faculties of Natural Sciences, Medicine & Health Sciences and Humanities & Social Sciences, the Pro-Vice Chancellor’s for Education, Research & Enterprise and Students and Directors of the professional service functions.

We have a global annual turnover of circa £170m. The University has the largest campus in the UK of around 618 acres and is home to 10,000 students.

The University is committed to exhibiting best practice in all aspects of corporate governance and to supporting the UK Government’s Action Plan to implement the UN Guiding Principles on Business and Human Right.

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.

Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

The University has comprehensive recruitment procedures and requires all staff partaking in the process to undertake mandatory training, to ensure legal compliance and best practice. Robust checks are carried out to ensure that all new staff have the right to work within the UK. Where it is necessary to hire external agency workers, our staff are directed to specified agencies that have undergone rigorous evaluation.
The University implements its own Whistleblowing Policy regarding concerns of illegal or unethical conduct. If any modern slavery cases were to be suspected on site, any alleged violation of human rights would be fully investigated and formal action taken as appropriate.

The University’s Safeguarding procedure ensures that our legal duty of care to safeguarding is undertaken. It provides details of the necessary steps should allegations be raised of harm or abuse (including Human Trafficking) against children or vulnerable adults.

Our people strategy and the University policies relating to modern slavery and our policies covering equality, diversity, safe guarding and whistle blowing can be found via the following links:

Supply chains

Modern slavery and human trafficking forms part of the University Sustainable Procurement Strategy.

The University has a supplier database of over 2,000 suppliers and our procurements can either be through a regional Higher Education purchasing consortium or through direct contracting. All procurement activities are managed through a centrally controlled Procurement department, which sits within the Finance Directorate.

The University purchases a wide range of products and services. Keele’s main categories of expenditure are as follows:

  • Laboratory consumables and equipment
  • Estate-related
  • Professional services
  • Library
  • IT equipment and services
  • Catering

We are working with our suppliers using an online tool provided by NetPositive Futures that asks and actively assists all our suppliers to develop an action plan that addresses Modern Slavery and other key sustainability issues within their businesses and supply chains. In this way, the University is taking pro-active steps to ensure its contracting arrangements comply with all the relevant legislation in both of these areas. We have contacted all of our suppliers to ask them about impacts arising from their business activities, including slavery within their supply chains and providing an opportunity for them to tell us how they are addressing these issues. The same process is used for all new suppliers. To date 890 of our suppliers have accessed the tool, and we are using the insights this provides to ensure that we recognise, encourage and support good practice.

To enable us to target our analysis to ensure we focus on areas at potential risk of incidents of modern slavery in their supply chain, we have analysed our supply base and identified the following areas for closer review:

  • Information technology equipment
  • Furniture
  • Catering
  • Construction and maintenance services

1. Information technology equipment
Forced labour is recognised as high risk in the electronic industry throughout developing countries. The University purchases the majority of its IT and IT consumables from framework arrangements that are managed by an HE consortium, the London Universities Purchasing Consortium (LUPC). The LUPC is a member of Electronic Watch, which is an independent monitoring organisation that assists public sector buyers to meet their responsibility to protect the human rights of electronics workers in their global supply chains.

2. Furniture
The University is a member of the North Western Universities Purchasing Consortium (NWUPC) and purchase the majority of its furniture from frameworks that are managed by the NWUPC. The levels of risk have been identified within the category strategy document by the NWUPC and appropriate actions considered. The University monitor’s risk at regular review meetings with suppliers using supplier actions plans which have been developed using the NetPositives Future tool.

3. Catering
As part of the University’s Sustainable Food Policy the University will prioritise ethical and responsible sourcing by purchasing high welfare meat and dairy products, source sustainable seafood that is Marine Stewardship Council (MSC)-certified and source fairly traded food, drink and other products for our operation. The University purchases its food-related items through frameworks which are managed by The University Caterers Organisation (TUCO) which is committed to ensuring that there is no modern slavery or human trafficking within its supply chains.

4. Construction and maintenance services
The University procures the majority of construction works by undertaking its own full procurement processes. All construction procurement's (irrespective of whether the value of the works is above or below the OJEU threshold) include as part of the selection stage evaluation a pass/fail assessment requiring the tenderer (and also each key subcontractor / each member of the bidding consortium as applicable) to confirm that either:

a. They are not a relevant commercial organisation as defined by section 54 of the Modern Slavery Act 2015 ; or
b. They are a relevant organisation and can demonstrate compliance with the annual reporting requirements contained within section 54.

The inclusion of this question in all construction procurement's is consistent with the governments procurement policy note on the Standard Selection Questionnaire and also reflects the importance of ensuring that all contractors to the University are meeting their obligations under the Modern Slavery Act. Successful contractors are encouraged to follow the Ethical Trading Initiative (ETI) base code which is an internationally recognised set of labour standards.

The University will occasionally procure works by doing a call-off under an existing Framework Agreement established by another contracting authority (which the University is eligible to use such as the Constructing West Midlands Framework) but will still include the same Modern Slavery pass/fail assessment within the further competition evaluation. Large maintenance services contracts procured by the University also follow the same approach.

Staff training and awareness

We are undertaking the following steps in order to raise awareness and understanding around the issue of modern slavery and human trafficking in supply chains:

  • A group of senior University officers will oversee current awareness activities and will meet at least annually to ensure adequate awareness raising is taking place
  • The group will ensure that the University’s annual modern slavery statement is up to date. The statement will be agreed by the University Audit and Risk Committee and signed off by the Vice-Chancellor.
  • Training will be undertaken by staff in those functional areas identified as requiring significant awareness of the risks regarding modern slavery such as Procurement and areas of commercial and estates activities.

Our plans for the future

We commit to better understand our supply chains in their entirety and work towards greater transparency and responsibility towards people working within them.

We will continue to implement and develop the following action plan to address the risks Modern Slavery and Human Trafficking represent in our business and supply chains:

  • We will continue to carry out supplier risk assessments and embed our MSA due diligence into the supplier and partner set up process
  • We will review and monitor supplier action plans through regular contract management and support initiatives to reduce the risk of Modern Slavery and Human Trafficking occurring
  • We will review and monitor supplier action plans developed through the NETpositive toolkit
  • We will continue to provide training for all key staff on MSA compliance, with a particular focus on People and Organisational Development and Academic Registry
  • We will continue to review and update all relevant policies and controls to embed MSA awareness

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 July 2018.

Professor Trevor McMillan
Keele University