Statement on the Modern Slavery Act
Modern Slavery Act 2015
Introduction
This statement is designed to satisfy the requirements of Part 6 Section 54 of the Modern Slavery Act (2015) (the Act).
The University's Ethics Statement states our commitment to the highest standards of ethical conduct in all our activities, along with making continuous improvements in this area. The University does not engage in, or condone, the practices of human trafficking, slavery or forced labour.
Structure of the business and supply chains
The University's supply chains mainly fall within the following 'top level' categories:
- Estates and Facilities Management (works, services and goods)
- ICT equipment and services
- Professional services
- Teaching materials
The University is a member of the London Universities Purchasing Consortium (LUPC) which has published its own Modern Slavery Statement and through whom the University has membership of Electronics Watch which works to protect the rights of electronics workers globally. Our membership of Electronics Watch via the LUPC means we can collaborate to minimise the risks of modern slavery.
In the 2019-20 financial year, the University undertook in excess of 13% of the value of our addressable spend through the London Universities Purchasing Consortium and other collaborative agreements available to the public sector.
The particular business and supply chains which may pose particular risks in terms of slavery are in facilities management, ICT & AV equipment, construction, and partnerships with overseas institutions in some jurisdictions. Our due diligence processes (below) minimise these risks.
Due diligence
Our due diligence process for the validation of new institutional partners, and arising agreements, includes requirements for compliance with the Act.
Our procurement process for new suppliers submitting UK level tenders, requires participants, through the standard selection questionnaire, to comply with the Act. We also use a supplier engagement tool (Net Positive Futures) to engage suppliers requesting that they review and confirm the arrangements they have in place to comply with the Act across their supply chains. All members of the procurement team have received training on use of the tool. Through our involvement with the LUPC and other organisations, the team share and keep up-to-date with best practice to identify and assess risks within supply chains.
Our facilities management services are provided by our wholly owned subsidiary, which pays the London Living Wage and does not employ unpaid interns. All centrally-tendered contracts now reiterate the University's commitment to fair work practices and paying above the minimum wage in line with the cost of living. We encourage our suppliers to do the same, pointing them to information about the real living wage.
Policies
The University has put in place a number of measures to ensure compliance with the Modern Slavery Act 2015. Our Corporate Social Responsibility Policy and Ethics Statement embeds Modern Slavery considerations, alongside other ethical business practices. The University Guide to Good Research Practice incorporates reference to the Ethics Statement and Modern Slavery.
Work will continue during 2021/22 to ensure compliance with the Act.
Andrew Boggs
University Clerk
September 2021
If any employee or worker of the University wishes to report any concerns or issues with the implementation of any of the University's policies or regulations they should refer to the University's Whistleblowing Policy.
Contact us
Kingston University
Tel: +44 (0)20 8417 9000
Contact us
Kingston University
Tel: +44 (0)20 8417 9000