²¤ÂÜÊÓƵ Modern Slavery and Human Trafficking Statement 2023
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act) and constitutes ²¤ÂÜÊÓƵ’s (BU) modern slavery and human trafficking statement for the financial year ending 31st July 2023. This is BU’s eighth statement and previous statements remain available here.
BU’s organisational structure
BU is a higher education provider created by statute and is an exempt charity. BU is responsible to the Office for Students (OfS) as principal regulator for Higher Education Institutions in England that are exempt charities. The BU Board oversees the strategic development of BU and ensures the effective use of resources and the solvency of the institution. Its members are also BU’s charitable trustees. Further details about BU’s structure and governance can be found on the BU website .
BU has undergraduate and postgraduate students who are attracted to BU from all over the world. BU is organised into several Faculties comprising; the Faculty of Health and Social Sciences, Faculty of Media and Communication, Faculty of Science and Technology, the ²¤ÂÜÊÓƵ Business School and also the BU Doctoral College. BU also has several professional service departments which include, amongst others; Finance, Academic Services, Estates, Marketing and Communications, Human Resources and Organisational Development, Student Services and IT Services.
BU has three wholly owned subsidiary companies; BU Innovations Limited, The ²¤ÂÜÊÓƵ Foundation and BU Community Business Limited. BU also undertakes collaborative work and enters into academic partnerships with other research organisations and businesses around the world.
BU’s student and staff activities
BU continues to have a staff member who chairs the CPS Wessex Modern Slavery Scrutiny Panel which reviews human trafficking and modern slavery cases across the region. BU academics are also in receipt of research funding on modern slavery prevention projects and BU graduates have also gone into employment with companies whose core mission includes prevention of modern slavery.
BU also raises awareness as part of the curriculum for students in relevant subjects. In March 2023 the former Anti-Slavery Commissioner, Dame Sara Thornton DBE QPM, visited BU and spoke to a cohort of ²¤ÂÜÊÓƵ students undertaking a Level 5 unit on Human Trafficking and Criminality. It is anticipated that she will repeat this visit in 2023/24 when over 200 students are enrolled on the course.
²¤ÂÜÊÓƵ supply chains and supplier adherence to BU’s values
BU’s supply chains for goods and services are complex and multi-tiered, and span from individuals to national and international entities. BU conducts annual diligence assessments with contracted suppliers to confirm their compliance with the Act. The due diligence process maintains focus on high-risk sectors within supply chains, which include; security services, construction/estates goods and services, catering/food supply chains, cleaning/domestic services, waste, ICT equipment/general electronics and clothing/textiles.
BU continues to seek assurances from suppliers and contractors of their compliance with the Act via our tender procedures (utilising Government’s standard Selection Questionnaire for all above threshold procurements), by contacting key suppliers in the higher risk areas, reviewing contracts with suppliers considering the need to prevent modern slavery and having Modern Slavery Act 2015 clauses in our ²¤ÂÜÊÓƵ standard terms of business for procurement and other supplier contracts.
BU policies and due diligence processes
BU implemented Anti-Slavery and Human Trafficking Policy and Procedures in 2016 which provide a reporting mechanism for all staff to raise concerns. The Policy and Procedures are formally reviewed and approved at least every two years and were most recently considered by the Audit, Risk and Governance Committee on behalf of the Board in November 2023. The Audit, Risk and Governance Committee has a standing agenda item to receive reports of any concerns raised under the Policy and Procedures and has oversight, along with the BU Board, of compliance with the Policy and Procedures. During the 2022/23 financial year no reports were received. The BU Whistleblowing (Disclosure in the Public Interest) Policy also protects staff, students and anyone working for BU (including casual workers, self-employed contractors, agency personnel) and allows them to raise concerns related to modern slavery or risk of modern slavery.
BU continues to mitigate the risk of modern slavery and human trafficking within its own staff community by following fair HR recruitment and selection policies and procedures. Where recruitment agencies are used, BU requires that such agencies comply with all UK legislation relating to the employment rights and welfare of candidates. BU also ensures that staff and students are able to access grievance procedures and raise concerns whether working remotely or on campus.
BU has a number of frameworks which underpin its ethical standards across all of its business activities. BU has also remained committed to playing its part in delivering the UN Sustainable Development Goals and worked to further embed the UN SDGs into all areas of BU. BU also continued to apply the following policies to ensure the procurement of goods and services took account of their social impact and to achieve ethical standards of business conduct; Sustainable Procurement Policy, Sustainable and Ethical Food Policy, Fair Trade Policy, Sustainability Policy, Sustainable IT Policy and Sustainable Construction Policy. BU also has an Ethical Investment Policy in which slavery and child labour are identified as areas in which investment is deemed inappropriate.
To ensure that ²¤ÂÜÊÓƵ takes full account of the economic, social and environmental implications of the goods, works and services it buys from external suppliers and organisations, BU utilises a suite of sustainability questions created by the Sustainability team which colleagues in Procurement and the Stakeholder select from when finalising the invitation to tender questions. Mandatory questions around compliance with the Act are included within the standard Central Government Selection Questionnaire for all above threshold procurements and similar questions are also included within BU’s £25,000 Public Contract Regulations threshold templates.
BU also continued to procure goods and services via consortium frameworks such as the Crown Commercial Service (CCS) and through its membership of the Southern Universities Procurement Consortium (SUPC) which is a membership-based buying organisation for universities and further education colleges.
Training and Raising Awareness
BU has dedicated representatives who are aware of the requirements of the Act from Legal Services and Corporate Governance, Human Resources, Procurement and Sustainability. During 2019/20 ²¤ÂÜÊÓƵ set up an Ethical/Responsible Procurement Group where slave labour matters were considered under the group’s oversight of the implementation of the Sustainable Procurement and Ethical Investment Policies. This group held its final meeting in May 2023 and oversight of slave labour matters has now been handed over to UET and the Sustainability Committee to ensure executive oversight.
BU remains committed to working with local charities and organisations to raise awareness in the community and will return to a programme of events when opportunities to collaborate arise.
As part of internal and external training sessions, BU ensures that relevant staff members are made aware of the risks of modern slavery and human trafficking in BU’s supply chains and its business.
BU’s effectiveness in combating slavery and human trafficking
BU will continue to review the effectiveness of its measures taken to combat slavery and human trafficking on a periodic basis and will review its approach against the new legislative measures expected from the Government following the transparency in supply chains consultation.
BU will monitor how the challenges of inflation impact on our ability to identify and address risks of modern slavery in our operations and supply chains through contract review meetings and in new procurements. BU will take such action as deemed necessary to maintain the highest levels of ethical and human rights principles in its business conduct and will monitor any emerging or heightened risks during the 2023/24 financial year.
Approval
This statement has been approved by the BU Board who, together with the Audit, Risk and Governance (ARG) Committee, will review and update it as necessary on an annual basis.
Approved by the ²¤ÂÜÊÓƵ Board on 24 November 2023 Signed by Jim Andrews Chief Operating Officer and University Board Member