Introduction

Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced 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.

We are committed to improving our practices to combat 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 July 31st 2018

Organisational Structure

The University of Bath is a provider of educational and research services within the Higher Education sector. The University of Bath operates primarily from its city of Bath campus in the UK and is made up of three Faculties, sixteen Departments, one School and four Institutes collectively sharing the organisational mission to deliver world-class research and teaching, educating our students to become future leaders and innovators, and benefiting the wider population through our research, enterprise and influence. We currently have c. 17,300 students and c. 3,200 staff. We had an annual turnover in 2017/18 of 288m.

Our Supply Chains

The University’s supply chains are global and complex supporting and reflecting the diverse range of activities carried out through our teaching, research and commercial partnerships. Our expenditure with third party suppliers during 2017-18 can be categorised at a high level under the following categories (the percentage split is indicative):

  • Estates and Construction 50%
  • Professional Services 12%
  • IT & Telecoms 7.2%
  • Laboratory & Medical 6.8%
  • Utilities 4.8%
  • Janitorial & Security 3.7%
  • Miscellaneous 3.7%
  • Library 3.3%
  • Travel & Transport 3.1%
  • Catering 3%
  • Office Supplies & Printing1.3%
  • Sports 0.6%
  • Furniture & Furnishings 0.5%

Our Policies

The University is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery-free, we operate and regularly review workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues. 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 in our supply chains.

Some of the University policies that support our approach to tackling modern slavery and human trafficking include:

Dignity and Respect Policy

This promotes a working and learning environment which will be stimulating and supportive and free of harassment, bullying and victimisation; where individuals are confident, if they bring a complaint in good faith, that the matter will be dealt with according to the agreed procedures without fear of subsequent victimisation or disadvantage. This policy applies to all staff (including casual and voluntary workers), honorary and visiting staff, volunteers and students and third parties (e.g. contractor, client or customer of the University).

Equality and Diversity Policies

This details how the University can be most effective in its impact on equality, diversity and inclusion and the elimination of harassment and discrimination (including our ‘#neverok’ campaigns).

Public Interest Disclosure Policy (Whistleblowing)

The University of Bath is committed to maintaining the highest standards of honesty, openness and accountability and to conducting its business in a responsible way. The policy encourages employees to raise their concerns in a responsible way where there is malpractice (that is, illegal, improper or negligent behaviour) or wrongdoing within an organisation and, where they do so, protects those employees from reprisal.

Health & Safety and Health & Wellbeing Policies

This sets out the expectations on employees, students, and contractors to support the University’s efforts to provide a safe and healthy workplace and to meet their own individual duty of care to others.

Safeguarding Policy

This aims to ensure the safety and welfare of children and adults at risk whilst on the University's premises or while engaging in activities controlled by the University.

Recruitment policy (employment checks)

This ensures our recruitment processes are non-discriminatory and that staff have a right to work in the UK, with checks made before they start work and that all immigration requirements are met as specified by UK Visas & Immigration (UKVI).

Due Diligence Processes for Slavery and Human Trafficking

We are evolving our category management approach to managing expenditure with third party suppliers to the University which allows us to manage supply chain risk by category and by supplier where necessary. Planned periodic reviews of our supply chains by category will allow the risks associated with modern slavery and human trafficking to be considered, identified and managed.

The University’s standard contractual terms and conditions used when procuring goods, service and works include provisions that embed the requirements of the Modern Slavery Act and provide the University with the powers to request information from our suppliers on the nature of their supply chains where necessary.

The University has developed a Responsible Procurement Code of Practice which documents our aims related to the environmental, social, economic and ethical impact, which includes modern slavery and human trafficking, when procuring all goods, services and works. This also makes it clear that all suppliers to the University are expected to comply with the principles of Responsible Procurement.

We are committed to using and selling ethically-sourced food in our hospitality outlets and catering services. In March 2018, we won the Gold Award for Best Fairtrade University, in recognition of our continued commitment to Fairtrade products, promotions and events, as well as our efforts over Fairtrade Fortnight. Fairtrade standards explicitly prohibit the use of forced labour and child labour. Independent auditors are used to look for evidence of abuse or discriminatory labour practices by employers, which are often indicators of modern slavery.

We follow the Public Contract Regulations when procuring goods, services and works. When the estimated value of the contract exceeds the EU value thresholds we ask all applicable bidding suppliers to confirm their compliance with the Modern Slavery Act.

We have applied for formal accreditation from the Living Wage Foundation to reinforce our commitment to ensure salaries keep pace with the cost of living. Once accredited the University will be committed to implementing that rate in common with other voluntary Living Wage employers. As part of this initiative we will request that relevant suppliers to the University also pay their staff the National Living wage or greater when delivering services to the University.

The University utilises a range of available framework agreements established by the buying consortium SUPC. This consortium is committed to ensuring modern slavery and human trafficking does not exist within their supply chains and requires suppliers operating within high risk industries to commit to the Base Code of the Ethical Trading Initiative (ETI). The ETI Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice, requiring that employment is freely chosen; freedom of association and the right to collective bargaining are respected; working conditions are safe and hygienic; child labour shall not be used; living wages are paid; working hours are not excessive; no discrimination is practised; regular employment is provided; and no harsh or inhumane treatment is allowed.

Further Steps

We will continue to evolve our working practices to ensure that the risks associated with modern slavery and human trafficking are managed effectively. In particular, during the 2018-19 financial year we aim to improve in the following areas:

All professional procurement staff will undertake training on Ethical Procurement provided by the Chartered Institute of Procurement and Supply.

Internal training delivered to University requisitioners will be updated to include further information related to combating modern slavery and human trafficking within supply chains.

We will highlight our commitment to tackling modern slavery and human trafficking to all new suppliers to the University. We will seek confirmation that all new suppliers have no convictions under the Modern Slavery Act and are compliant where relevant, and will request that they adopt the principles of Responsible Procurement when supplying the University.

We will develop a detailed questionnaire for use with new and existing suppliers that are identified as high risk with regard to modern slavery and human trafficking with the aim of obtaining detailed information about their respective supply chains.

We will ask more detailed questions to prospective suppliers related to supply chain risk when bidding for contracts with a value greater then 25k.

We will further promote the University Public Interest Disclosure Policy (Whistleblowing) reiterating its role in reporting instances of suspected modern slavery or human trafficking throughout any part of the University operation.

Approved by Mrs Ruth Foreman, Acting Chair of Council, on 21 January 2019