Modern Slavery Act
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Nottingham Trent University's slavery and human trafficking statement for the financial year ending 31 July 2018.
Nottingham Trent University is a Higher Education Corporation established in accordance with the Education Reform Act 1988. We are a provider of education and research services and comprise three Colleges, each in turn hosting a number of Schools:
College of Business, Law and Social Sciences
- Nottingham Business School
- Nottingham Law School
- School of Social Sciences
- Nottingham Institute of Education
College of Art, Architecture, Design and Humanities
- School of Art & Design
- School of Architecture, Design and the Built Environment
- School of Arts and Humanities
College of Science and Technology
- School of Science and Technology
- School of Animal, Rural and Environmental Sciences
together with the NTU Doctoral School and a number of professional services directorates.
The University has a global annual turnover of £300 million and a procurement spend of £109 million.
The University also has a number of subsidiary companies through which its commercial activities are provided.
The University will not tolerate modern slavery or human trafficking in its supply chains or in any part of its business. It has employment policies and codes of conduct in place which have relevance to how this issue is addressed within its business by members of its staff.
In light of the obligation to report on measures that seek to ensure that all parts of the University's business and supply chain are slavery free the University has reviewed its workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.
These reinforce the University's commitment to acting ethically and with integrity in all its business relationships and 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 and Facilities Management
- Information Systems, including hardware, software and services
- HR and Professional Services
- Catering Services
- Libraries and Publications
- Marketing, Print, Stationery and Travel
- 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
- 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 Purchasing and other Consortia framework agreements.
The U.K. 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.
Supporting Actions Completed in 2018
1. Development of Modern Slavery Information Materials for University Staff
- Information materials have now been developed and are being used to raise general awareness for staff across the University via the University’s intranet.
- More detailed information materials have also been developed and are being shared with key staff groups including Estates and Information Systems.
2. Flexible Framework Assessment
The Flexible Framework monitors supply chain sustainability aspects including Modern Slavery. An external assessment was carried out in July 2018, which confirmed that the University continues to fulfil the requirements of Level 4 and is part way to achieving Level 5, the highest Level obtainable. The Framework monitors supply chain sustainability aspects and feeds into out LifeIndex score and ISO14001 accreditation.
3. NETpositive Supplier Engagement Tool (SET)
The University continues to encourage its suppliers to use the NETpositive Supplier Engagement Tool (SET), a database system which collects information from suppliers on sustainability issues, including Modern Slavery and Human Trafficking.
There are currently 841 of the University’s suppliers registered on the SET database. Out of these 811 (96.41%) have stated that they are aware of the Modern Slavery Act. The remaining 30 suppliers are currently being contacted to engage with them and improve their awareness of Modern Slavery and Human Trafficking.
The University’s Procurement Team is monitoring suppliers’ use of the SET, in particular, the questions and actions relating to Modern Slavery.
The Procurement Team has lobbied 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.
5. 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 regarding Modern Slavery and Human Trafficking in the supply chain.
A review of Modern Slavery and Human Trafficking statements published by HEIs was carried out this year. The subsequent Guidance for HEIs on Preparing a Slavery and Human Trafficking Statement is also being consulted for best practice.
6. Establishment of a Working Group
A Modern Slavery Group has been established. Progress is being monitored and reported back to the Sustainable Development Operational Forum. This Forum, chaired by the Chief Operating Officer and Registrar, covers all areas of sustainable development, which includes modern slavery and human trafficking issues.
In addition to overseeing any current and proposed actions the Modern Slavery Working Group includes the following areas in its scope:
- 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.
- Monitoring the number of NTU suppliers:
- Registered with NETpositive; and
- Actively using NETpositive for self-assessments.
- 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.
- Reviewing the potential benefits of other approaches, including:
- Membership of organisations such as SEDEX and Electronics Watch, which facilitate the carrying out of audits by their supplier membership and act as a repository for audit reports accessible to their customer membership. Membership of both organisations has been set up for 2018/19 and how best to use the resources available to engage with and monitor suppliers is being fully investigated.
- Continuing to lobby 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
- Investigating opportunities to take part in wider programmes, for example the University of Nottingham Research project to “help make Nottingham a slavery-free city”, or other such national initiatives.
Supply chain policies
The latest update of 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 updated Sustainable Procurement Policy. In addition, standard contract terms and conditions and tender documents have been amended to reinforce this requirement. An appropriate Modern Slavery clause has been inserted into the Standard Conditions of Contract which are visible to suppliers on the Procurement website.
The University has clarified that staff with any concerns about potential modern slavery abuses could report this in two ways:
- Internally via the University 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 Department has the following processes in place:
- Controls within University procurement procedures to ensure that the tendering process for new suppliers and contractors and the management of the performance of, and relationship with suppliers and contractors includes compliance with the University's policies, including policies relating to modern slavery and human trafficking.
- To check 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.