Modern Slavery Act Transparency Statement 2022/23

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by the University of Chester (including its wholly owned subsidiary companies) during the financial year ending July 2023 to prevent modern slavery and human trafficking in its business and supply chains. This statement has been approved by University Council on 28th November 2023.

1. INTRODUCTION

1.1 This is the University of Chester’s fourth statement issued under the Modern Slavery Act and it outlines the steps we have taken (and continue to take) as an organisation to prevent modern slavery and human trafficking in our business and supply chains.

1.2 The University recognises and understands that:

  1. modern slavery is present across the world including in every single area of the UK and that the number of people identified as victims of modern slavery has been rising year on year;

  2. modern slavery is a crime and a violation of fundamental human rights;

  3. modern slavery can take many forms and may involve multiple forms of exploitation, that it is often hidden and can be difficult to recognise (even to the victims themselves) especially in our complex modern-day supply chains and globalised business practices; and

  4. it is not enough for governments and organisations simply to say that they don’t tolerate modern slavery but that there must be decisive and collective action to drive out modern slavery.

1.3 In the past year, the University has taken the time to deepen its understanding of the risks and issues associated with modern slavery and human trafficking and to adapt its existing measures as well as introduce new measures to mitigate such risks. This work has included the establishment of a Modern Slavery Working Group with representatives from across the professional services and academic teams to ensure a University wide approach.

1.4 The University has also had to take into account the global impact of many things including post Covid-19 impact, cost of living crisis, war and unrest which has resulted in disruption and change on an unprecedented scale including to those people who are enslaved or vulnerable to slavery, where the economic and social disruption caused may be affecting their lives in new and profound ways. In the UK, Brexit and the ending of freedom of movement has also had a significant impact against our collective efforts against modern slavery and reinforces the importance of keeping our existing practices and processes under constant review as well as encouraging others to do so in order to combat modern slavery and human trafficking.

1.5 The University, as a socially responsible institution is committed to playing its part in eradicating modern slavery and human trafficking and to uphold and respect the fundamental human rights of all individuals who have dealings with the organisation including its employees, students, supply chain workers, customers, stakeholders and its local and global communities. The University accepts its responsibility to support transparency, to carry out supply chain mapping and due diligence, to keep its business practices relevant and under review and to encourage and collaborate with others to protect and promote the rights of those who are most vulnerable to abuses such as modern slavery and human trafficking.

2. OUR BUSINESS AND ORGANISATIONAL STRUCTURE

2.1 The University was founded as Chester Diocesan Training College in 1839 and established by Deed dated 13th January 1843, which was further regulated, augmented, supplemented and varied by Deeds and Schemes from 19th February 1858 onwards.

2.2 On 22nd July 2005 Her Majesty’s Privy Council approved use of the name University by the institution.

2.3 Chester Diocesan Board of Finance is the University’s custodian trustee and the Members of the University Council are the University’s management trustees. The University Council is responsible for setting and approving the University’s mission, strategy and policies and the Chief Executive (Vice-Chancellor) is responsible for managing the day to day operations of the University, supported by the University’s Strategic Executive Team.

2.4 The University is a non-exempt charity registered under Charity Number 525938.

Principal Activities of the University

2.5 The principal activity of the University is the provision of higher education and related teaching and research. The University currently has a population of over 14,000 students and 1,500 full and part time staff across several sites drawn from across the UK and internationally. The University is composed of three academic faculties sub-divided into a wide range of discipline areas, supported by professional services and administrative departments. Further details about our organisation can be found in our about section.

2.6 The University has an annual income of £138 million of which approximately 30% is spent on average on goods, services and works through various supply chains each year.

Values and Commitments

2.7 The University’s mission, institutional values and commitments are embedded in its Citizen Student strategy and the University has a number of workplace policies and procedures which embed these values into its day-to-day activities. Staff and students are expected to report concerns, using the appropriate reporting channels and management is expected to act on those concerns.

3. OUR SUPPLY CHAINS

3.1 The University recognises that its biggest exposure to Modern Slavery lies in people and in its supply chains.

People

Employment of Staff

3.2 Most of the University’s personnel resource is directly employed; few services are outsourced or supplied through agencies. The University mitigates the risk of modern slavery occurring by ensuring that directly employed staff are recruited following robust HR recruitment and candidate selection Temporary staff (including students seeking part-time paid employment) are recruited predominantly by means of the University’s own bank of available staff. There is a whistleblowing policy through which staff can raise concerns.

3.3 Staff recruited indirectly by the University or outsourced staff are only recruited through established and accredited sources who can provide assurance that they fully comply with the requirements of all legislation relating to the rights and welfare of their candidates and employees.

3.4 The University is committed to promoting the welfare of its staff and to ensuring that its staff are paid appropriately for the work they carry out.

Students

3.5 The University has a large student population, some 18% of which being international students including students from countries with poor human rights records. The University recognises that students from these countries may be particularly vulnerable to modern slavery and human trafficking particularly as they may be unfamiliar with our laws and practices.

Whilst the University believes that the risks of students experiencing occurrences of modern slavery or human trafficking through direct contact with the University are extremely low, it is recognised that whilst living in Chester and Warrington and surrounding areas, they may become aware of such instances or rarely be entrapped into adopting a lifestyle of modern slavery. In order to mitigate these circumstances, the University has in place easily accessible and well publicised channels through which students can obtain assistance, support and advice on their wellbeing. With regards to International or migrant students the University ensures that it undertakes both attendance and engagement monitoring in relation to individual students’ academic activity. Where a student has low or erratic engagement the University will reach out to the individual student to ascertain what barriers to study exist. This does on occasions highlight vulnerable persons and the appropriate internal and/or external wellbeing services are informed.

The University also encourages all migrant students to live within the immediate Chester area, or the appropriate site of study. Audits of migrant students’ addresses are undertaken and where it is found that a migrant student is living at a distance from the University and is not engaging as would be expected appropriate action is taken.

Supply Chain

Supply Chain and Procurement

3.6 The University’s campus comprises multiple buildings across Chester, Warrington, Birkenhead and Shrewsbury and requires a large and complex supply chain to support its activities and operations.

3.7 The University has a supplier database of around 6,796 of which 2,102 were actively used in 2022-23. University suppliers are procured either through a regional Higher Education purchasing consortium, NWUPC, or through direct contracting pursuant to the University’s procurement policies and procedures. All procurement activities are supported and managed centrally by the University’s Procurement Services team, which is located in the University’s Finance Directorate.

3.8 The University purchases a wide range of products and services from a diverse range of suppliers, most of which are primarily based in the UK. The main categories of expenditure are as follows:

  • Consumables and equipment
  • Estates-related
  • Professional services
  • Library
  • IT equipment, subscriptions and services
  • catering

3.9 Given the global nature of supply chains generally and in particular where goods and/or services may be procured from international suppliers, from outside of the UK or from suppliers with international supply chains, we recognise that there may be an increased risk of Modern Slavery occurring, particularly in high risk industries and high-risk countries.

3.10 The University already includes questions in its tender documents asking potential suppliers if they are required to publish a Modern Slavery Act statement and if they are, whether they are compliant with the reporting requirements.

3.11 NWUPC Ltd is an affiliate member of Electronics Watch on behalf of its members including University of Chester. Electronics Watch is an independent monitoring organisation set up with the purpose of protecting the rights of workers within supply chains.

3.12 The University has continued to actively promote the NETpositive Supplier Engagement tool which enables suppliers to develop a free Sustainability action plan. Within the action plan suppliers are asked about their commitment to Modern Slavery. During 2022-23 we identified 8 further large suppliers registered on NETpositive who had not responded about whether they have a Modern Slavery statement. We emailed these suppliers encouraging them to update their information as part of the University’s support in working with suppliers to develop Modern Slavery Statements and monitor supply chains.

3.13 During 2022-23 as part of their continuing development all three members of the Procurement Services team have undertaken the HEPA/BUFDG course “A Guide to Modern Slavery”, which is under HEPA’s Compliance training section. In addition, they will, or have already taken the Protecting Human Rights in the Supply Chain course available from HEPA/BUFDG under their Procurement training section.

4. OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

4.1 The University is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its business. The University keeps under review its workplace policies and procedures to ensure their effectiveness in identifying and tackling modern slavery issues. The University has also adopted a  and an Anti- Slavery and Human Trafficking Policy which reflect the University’s commitment to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place anywhere in its supply chains.

4.2 Awareness and understanding of the risks of modern slavery and human trafficking in the University’s supply chains and business is raised through the provision of appropriate staff training.

4.3 The University’s contractual documentation includes obligations regarding compliance with modern slavery legislation as well as the right to terminate in the event of a breach of these obligations.

5. DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of the University’s initiative to identify and mitigate risk, the University will continue to put systems in place to:

  • identify and assess potential risk areas within its organisation and supply chains; mitigate the risk of slavery and human trafficking occurring anywhere within its organisation or supply chains; and
  • monitor potential risk areas within its organisation and supply chains.

6. OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING

In order to assess the effectiveness of the measures taken by the University we will be reviewing the following key performance indicators and reporting on them in future Modern Slavery Statements:

  • Staff training levels
  • Actions taken to strengthen supply chain auditing and verification
  • Steps taken to raise awareness of modern slavery and human trafficking amongst employees and students;
  • Investigations undertaken into reports of modern slavery and any action taken in response;
  • Involvement in modern slavery and human trafficking prevention initiatives, research, partnership and collaborations aimed at tackling modern slavery and the promotion of a shared culture of best practice.

7. FURTHER STEPS

7.1 The University is committed to greater understanding, transparency and responsibility towards people including people working within its supply chains.

7.2 Notwithstanding the steps already identified above, the University intends to take the following further steps to combat slavery and human trafficking:

  • keep under review the University’s contractual documentation to ensure ongoing compliance with the Modern Slavery Act 2015 and encourage suppliers and stakeholders work with the University in tackling modern slavery;
  • keep under review the University’s procurement documentation and processes to ensure they reflect best practice and support the University’s objectives on this area;
  • keep under review the University’s workplace policies and procedures to ensure their effectiveness in identifying and tackling modern slavery issues;
  • keep under review and incorporate relevant material within the programme of ongoing risk and compliance training for all staff including senior staff and managers;
  • positive engagement in initiatives, research, partnerships and collaborations aimed at tackling modern slavery and promoting a shared culture of best practice;
  • the ongoing implementation and enforcement of effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in its supply chains;
  • procurement services will engage further with University suppliers to promote the NETpositive Supplier Engagement tool and encourage an increase in reported actions in relation to Modern Slavery with their supply chains.

 

Professor EA Simmons
Vice-Chancellor and Principal

Date: 28th November 2023