Slavery and human trafficking statement

a) Assessment regarding high-risk areas takes place as part of the procurement process. During 2025 we re-tendered for the following contracts in high-risk sub-categories:

• Promotional Merchandise and Sports Clothing; both of which had increased sustainability requirements factored into the tenders and evaluation assessments;
• A new framework for Small Building Works Contractors for which, in addition to increased sustainability requirements, NTU Procurement carried out face to face onboarding meetings with suppliers to reinforce sustainability requirements; and
• For Digital Technologies, sustainability-focused meetings have taken place with contracted suppliers for laptops and desktops, plus engagement with Electronics Watch to undertake an assessment of supply chains involved in producing the hardware purchased most frequently. In new tenders for laptops, desktops and AV, modern slavery requirements have been strengthened.

b) Reviewing the potential benefits of other approaches, including:

• Continuing to work with HE Procurement Consortia or other organisations such as BUFDG (British Universities Finance Directors Group), to put in place appropriate sector-wide arrangements that NTU could ‘call off’ from as appropriate; and
• Continue to work with the University of Nottingham, and other local universities sharing information on suppliers who exist in both UoN and NTU supply chains and exploring opportunities for collaboration as they arise.

The Supplier Engagement Tool enables NTU Procurement to review modern slavery commitments and details of:

• any modern slavery disclosed within organisations or supply chains (in the past three years);
• approaches to provision of modern slavery training;
• any supply chain risk analysis;
• suppliers’ formal processes for responding to potential incidences; and
• mechanisms for staff reporting suspected incidents.

The total number of suppliers traded with during the last year, who are signed up to the tool, has risen from 126 to 250. The number of suppliers used each year varies, given the dynamic nature of the University’s supply chain, but for 2024/25 this accounts for almost 60% of the total number of suppliers.

The Procurement Policy, the Sustainable Procurement Policy and the Supplier Code of Conduct include reference to the prevention of Slavery and Human Trafficking in the supply chain. 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 includes compliance with the University’s policies, including policies relating to modern slavery and human trafficking; and
• Checks that similar provisions are contained within 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.

• As part of the University’s induction programme, colleagues are encouraged to complete the BUFDG 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 with purchasing responsibilities.
• 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.

The Flexible Framework monitors supply chain sustainability aspects including Modern Slavery. Following the original Flexible Framework external assessment carried out in July 2018 this is reviewed each year internally to ensure the University continues to fulfil the requirements of Level 4.

The Framework monitors supply chain sustainability aspects and feeds into the University’s ISO14001 accreditation.

The Procurement team continues to work with BUFDG and other Purchasing Consortia to consider incorporating Modern Slavery clauses into all new HE framework contracts.

In an effort to influence some of NTU’s SMEs to develop modern slavery processes, the Sustainable Procurement Manager met with NTU’s (NEUPC) consortia Responsible Procurement Manager to broaden knowledge on free tools and resources beyond the NETpositives Supplier Engagement Tool (including but not limited to UNSEEN SME Business Toolkit, Sustainability Supply Chain School, etc.).

The Sustainable Procurement Manager maintains awareness of work and best practice as a member of the BUFDG & EAUC (Environmental Association for Universities and Colleges) Responsible Procurement Steering Group and through its associated guidance and communications. 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.

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.