Modern Slavery Act

Modern Slavery and Human Trafficking Statement

Modern slavery is a crime and a violation of fundamental human rights under the Modern Slavery Act 2015. It takes various forms, including 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 modern 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, to ensure 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. Membership of UEC comprises of the Vice-Chancellor (chair); the Deputy Vice-Chancellor and Provost; the Chief Operating Officer; Pro Vice-Chancellors; Deans of the Faculties; and Directors of the professional service functions.

The University has a global annual turnover of circa £170m; is one of the largest campus universities in the UK of 600 acres, and is home to approximately 10,000 students.

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

Our policies on slavery and human trafficking

The University endeavours to ensure 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 participating in the process to undertake recruitment training which includes content relating to modern slavery and human trafficking, in order to support legal compliance and best practice in this area. 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 appropriate evaluation.

The University implements its own Whistleblowing Policy regarding concerns about 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 recognises that it has a legal duty of care with respect to safeguarding and has put appropriate procedures in place in relation to this. The Safeguarding Policy (and associated Safeguarding Procedure) provides details of the necessary steps to be taken should allegations be raised of harm or abuse (including human trafficking) against children or vulnerable adults.

Our People Strategy and the University’s policies covering equality, diversity, safeguarding and whistleblowing can be found via the following links:

Supply chains

Modern slavery and human trafficking forms part of the University’s 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. The main categories of expenditure are as follows

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

We work 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 proactive steps to ensure its contracting arrangements comply with all the relevant legislation in both of these areas.

We contact 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 996 of our suppliers have accessed the tool and we are using the information to understand the status of these activities in our supply base and to 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 the supply chain, we have analysed our supply base and we continue to monitor the following high-risk areas:

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

1. Information technology equipment
Forced labour is recognised as a high risk in the electronics industry throughout developing countries. The University purchases the majority of its IT and IT consumables from framework arrangements that are managed by a Higher Education consortium: the London Universities Purchasing Consortium. The University is a member of The North Western Universities Purchasing Consortium (NWUPC). NWUPC is an affiliate member of Electronics Watch on behalf of its members. Electronics Watch 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
As a member of NWUPC, the University purchases 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 monitors risk at regular review meetings with suppliers using supplier action plans which have been developed using the NetPositives Future tool.

3. Catering
As part of the University’s Sustainable Food Policy the University prioritises ethical and responsible sourcing by (a) purchasing high welfare meat and dairy products; (b) sourcing sustainable seafood that is Marine Stewardship Council certified; and (c) sourcing fairly traded food, drink and other products for our operation. The University purchases food through frameworks which are managed by The University Caterers Organisation Ltd 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 and maintenance services in line with its tendering procedures, whereby all construction procurements (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/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 commercial organisation and can demonstrate compliance with the annual reporting requirements contained within section 54 of the Modern Slavery Act 2015.

This approach is consistent with the Government’s Procurement Policy Note: Standard Selection Questionnaire. Successful contractors are encouraged by the University to follow the Ethical Trading Initiative Base Code which is founded on the conventions of the International Labour Organisation and is an internationally recognised code of labour practice.

The University will occasionally procure works via a call-off under an existing public sector framework agreement established by another contracting authority 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 continuing to undertake the following steps in order to raise awareness and understanding regarding the issue of modern slavery and human trafficking in supply chains:

  • A group of senior University officers oversees current awareness activities and meets at least annually to ensure adequate awareness- raising is taking place.
  • The group ensures that the University’s annual Modern Slavery and Human Trafficking Statement is up to date. The statement is agreed by the University Council and signed off by the Vice-Chancellor.
  • Training is 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-related activities, over 100 staff have completed an e-learning module on Modern Slavery and Human Rights.

Our plans for the future

We commit to better understand our supply chains. We will continue to implement and develop the following action plan to identify and mitigate any risks that Modern Slavery and Human Trafficking represent in our business and supply chains:

  • We will continue to raise awareness of modern slavery issues amongst our suppliers and staff, encourage transparency amongst our suppliers and continue to carry out supplier risk assessments where concerns arise. Sharing our due diligence practices in relation to modern slavery and human trafficking with our suppliers and partners.
  • 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 continue to review and monitor supplier action plans developed through the NETpositive toolkit.
  • We will continue to provide training for relevant staff on compliance with the Modern Slavery Act 2015.
  • We will continue to review and update all relevant policies and controls in order to embed awareness in relation to modern slavery and human trafficking.

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 2020.

Professor Trevor McMillan
Keele University

February 2021