Slavery and human trafficking statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Nottingham Trent University’s (NTU) slavery and human trafficking statement for the financial year ending 31 July 2022.
Nottingham Trent University is a Higher Education Corporation established in accordance with the Education Reform Act 1988. It is a provider of education and research services and comprises the following:
- Nottingham Business School;
- Nottingham Law School;
- School of Animal, Rural and Environmental Sciences;
- School of Architecture, Design and Built Environment;
- Nottingham School of Art and Design;
- School of Art and Humanities;
- School of Science and Technology;
- School of Social Sciences;
- Confetti Media Group; and
- The NTU Doctoral School, NTU in Mansfield and several professional services directorates.
The University’s income for the year is in excess of £400 million and it has a procurement spend of £122 million.
The University will not tolerate modern slavery or human trafficking in its supply chains or in any part of its business. It has workplace policies (including employment), procedures and codes of conduct in place which have relevance to how this issue is addressed within its business by members of its staff.
These reinforce the University’s commitment to acting ethically and with integrity in all its business relationships. To implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within the University.
Our supply chains
The University’s supply chains are generally captured within the following categories:
- Estates, Facilities Management and Waste Services;
- Digital Technology (including hardware, software and services);
- HR and Professional Services;
- Catering Services;
- Libraries and Publications;
- Marketing, Print, Stationery and Travel; and
- Agricultural, Medical and Laboratory.
The sub-categories that carry a raised risk in terms of slavery and human trafficking have been assessed as:
- Construction works sub-contractors and supply chains;
- Estates hard and soft Facilities Management Services (such as maintenance, cleaning and security services);
- Labour Agencies;
- IS personal computers, laptops and multi-functional devices;
- Audio Visual (AV) equipment and products;
- Laboratory supplies;
- Workwear Clothing;
- Food production and supply; and
- Promotional Merchandise / Office Supplies / Stationery.
A wide range of products are procured across all of these sub-categories, some of which are sourced from international manufacturers operating in low-cost countries. For some of these sub-categories the University sources its requirements through Higher Education Procurement Association and other Higher Education Purchasing Consortia framework agreements.
The UK Construction Industry is heavily regulated by statute in relation to Health & Safety, Employment Law, Building Regulations and similar. The Estates Procurement team makes regular use of established contractor screening processes when selecting companies to undertake works or services for the University.
To aid with screening, NTU have affiliate membership to Electronics Watch (via NEUPC (North Eastern Universities Purchasing Consortium) joint subscription).
Actions Completed in 2022
1. A Sustainable Procurement Project Manager and Sustainable Procurement Project Assistant have been appointed (for a fixed term period). While their focus will be on Net Zero (scope 3 supply chain carbon emission reductions), their roles will encompass Modern Slavery.
2. Development of Modern Slavery Information Materials
- Information materials continue to be used to raise general awareness for colleagues across the University and shared via the University’s intranet.
- As part of the University’s induction programme, colleagues are encouraged to complete the Higher Education Procurement Association (HEPA) Guide to Modern Slavery Course. This is mandatory for all colleagues within the Procurement team.
- Modern Slavery awareness is included within Essential Purchasing Training and Purchasing Card Training for those colleagues working within that area.
- More detailed information materials are shared with key staff groups including Estates and Digital Technology which incorporates sustainable development elements of the Modern Slavery Act via NTU’s Sustainable Awareness training.
3. Flexile Framework
The Flexible Framework monitors supply chain sustainability aspects including Modern Slavery. Following the original Flexible Framework external assessment carried out in July 2018 and reviewed in October 2020 the University continues to fulfil the requirements of Level 4.
Due to the higher commitment required for Level 5 (the highest Level obtainable) it has been decided that we do not progress to Level 5 at this stage instead focusing on ensuring we improve continuously our achievements against Level 4 year on year. The Framework monitors supply chain sustainability aspects and feeds into our ISO14001 accreditation.
4. NETpositive Supplier Engagement Tool
The University continues to encourage its suppliers to use the NETpositive Supplier Engagement Tool, a HE sector database system which aids suppliers to develop sustainability action plans (providing prompts and information to do so), and also allows universities to assess their suppliers on sustainability issues, including Modern Slavery and Human Trafficking.
The University has committed to a target to increase the number of supplier’s registered with the tool by a further 20% this year.
NTU Procurement commit to focus on raising the profile and importance of the tool to suppliers in 2022/23. As such, a review of existing supplier actions plans will be undertaken so that appropriate measures can be taken to raise engagement and ensure suppliers are delivering tangible sustainability actions).
The Procurement team continues to work with the Higher Education Procurement Association (HEPA) and other Purchasing Consortia to incorporate Modern Slavery clauses into all new HE Framework contracts. Where framework agreements do not have appropriate Modern Slavery clauses NTU-specific additional clauses are included for use within mini-tenders.
6. Sector Best Practice
The University maintains awareness of work and best practice in the HE sector via the HEPA Responsible Procurement Working Group, of which it is an active member. Awareness of this issue from outside the sector is maintained by following the latest advice and recommendations published by the Chartered Institute of Procurement and Supply (CIPS) regarding Modern Slavery and Human Trafficking in the supply chain.
7. Modern Slavery Working Group
The Modern Slavery Working Group monitored progress throughout the year and reported to the Embracing Sustainability Strategy Board (ESSB). The Board, chaired by the Chief Operating Officer and Registrar, covered all areas of sustainable development, which included modern slavery and human trafficking issues. Meetings took place five times during the year. The ESSB has now ceased to meet and in order to reflect the growing scope of sustainability for NTU’s procurement team, a Sustainable Procurement Working Group has been established which will now encompass the work of the Modern Slavery Working Group.
In addition to overseeing any current and proposed actions the Modern Slavery Working Group includes the following areas in its scope:
a) Monitoring the level of supply chain incidents reported including a review of remedial action taken where non-compliance may have been identified - none have been reported so far.
b) Monitoring the number of NTU suppliers:
- Registered with NETpositive; and
- Actively using NETpositive for self-assessments.
c) Developing proposals identifying appropriate levels of proactive checks or audits to be made on higher risk NTU supply chains, following analysis of current HE and public sector best practice.
d) Reviewing the potential benefits of other approaches, including:
- Continuing to work with HE Procurement Consortia or other organisations such as HEPA, to put in place appropriate sector-wide arrangements that NTU could ‘call off’ from as appropriate; and
- Working with academics at the University who have carried out research into modern slavery, trafficking and exploitation and whose expertise can inform the approach taken by the University. Further information is set out below at section 8.
8. Academic Research
NTU has several academics whose research relates to modern slavery, trafficking and exploitations. The Work, Informalisation and Place Research Centre at NTU, jointly operated between the Nottingham Business School and the School of Social Sciences, provides a focus for the University’s research work. This research centre explores the interconnected issues of labour market exploitation, the informal economy and place and looks at modern slavery within a spectrum of offences that affect a large minority of workers in the UK. It has completed a research project exploring the link between Covid-19, modern slavery and three work sectors at sites across the UK. Its work has informed also policy and practice activity at a local and national level helping to shape the office of Labour Market Enforcement strategies, Gangmaster and Labour Abuse Authority enforcement work and the work of an independent licensing scheme to improve conditions and work practices in hand car washes which is one of the work sectors most reported to the Modern Slavery helpline.
The research centre and by association NTU has been a founding member of the Midlands Anti-Slavery Research Collaboration launched by Lord Coaker to raise issues of modern slavery and exploitation across the Midlands with policymakers and the public. This partnership includes work with colleagues in the department of Crime and Criminal Justice in the School of Social Sciences and in Nottingham Law School research is undertaken on the link between the asylum process, poverty and ultimately labour exploitation.
9. Supply Chain Policies
The Procurement Policy includes reference to the prevention of Slavery and Human Trafficking in the supply chain. The Supplier Code of Conduct expected of all University suppliers requires compliance with Modern Slavery legislation, as does the Sustainable Procurement Policy. In addition, standard contract terms and conditions and tender documents reinforce this requirement. An appropriate Modern Slavery clause is included in our Standard Conditions of Contract which are visible to suppliers on the Procurement page of the NTU website.
Colleagues with any concerns about potential modern slavery abuses can report this in two ways:
- Internally via the University’s Whistle-blowing Policy to enable a confidential and comprehensive investigation to be undertaken; and / or
- Externally to the anonymous National Reporting Line at 0800 0121700, so that any concerns can be included in wider investigations by the relevant authorities into suspected abuses at a Regional and National level.
The University expects that all suppliers and contractors in its supply chain will comply with its values. To help ensure this the Procurement team has the following processes in place:
- Controls within University procurement procedures to ensure that the tendering process for new suppliers and contractors and includes compliance with the University’s policies, including policies relating to modern slavery and human trafficking; and
- Checks that similar provisions are contained within Higher Education Purchasing and other Consortia framework agreements used by the University. In the event that the University wished to use a framework agreement which did not contain such a protection, it would seek to include such a provision by negotiation.
Approved by the Board of Governors on 22 November 2022.