The University is committed to measuring and actively monitoring that modern slavery and human trafficking is not taking place in any parts of its operation within the University and its supply chain.
Under the Modern Slavery Act, the University is committed to ensuring there are no instances of modern slavery, human trafficking, forced and bonded labour and labour rights violations in its supply chains, and that the following principles are adhered to:
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 practiced
Regular employment is provided
No harsh or inhumane treatment is allowed
|Author||Head of Procurement|
|Approved By||Senior Management Team|
|Approval Date||1st December 2021|
|Review Date||Autumn 2022|
|Activity/Task||University Governance/Procurement Compliance|
|Procurement Web Page|
|Sustainability Development Policy||An overview of the commitment to sustainable development|
|Purchasing and Procurement Manual||To provide guidance to staff involved in purchasing goods, services and works on behalf of Abertay University|
|Human Resource/People Services Policies||Several HR/PS policies can be applied to the subject matter, all are located on the People Services intranet page.|
|Whistleblowing policy||To encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected|
|Version Number||Purpose / Changes||Author||Date|
|2021.1||New Policy to comply with legislation||Head of Procurement||Autumn 2021|
The purpose of this document is to ensure that Abertay University meets its obligations under the terms of the Modern Slavery Act 2015, ensuring that there is no modern slavery or human trafficking in the University’s supply chain or any other part of its business.
This Policy reflects our commitment to acting ethically and with integrity in our business relationships in addition to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not tolerated in any part of its business.
Modern Slavery and Human Trafficking is a criminal offence under the Modern Slavery Act 2015 (the Act).
In 2015, the UK government passed the Modern Slavery Act. The Act applies largely to England and Wales. Limited parts of the Act are enforceable in Scotland. The sections that apply in Scotland relate to the seizure of ships by relevant authorities, and the appointment of an Independent Commissioner. The matters in this policy refer to Part Six of the Act (Transparency in Supply Chains, etc.) as it relates to the procurement and supply chain management of the Abertay University.
A Practical Guide has been published by Westminster as guidance for how Part Six of the Act can be dealt with https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide
The legal definition in Scotland is set out in the Human Trafficking and Exploitation (Scotland) Act 2015. In simple terms it is trading adults and children for the purpose of personal gain or profit. It is a violation of human rights, preying on some of the most vulnerable in society. It often involves long-term exploitation and its effect on victims can be devastating.
Human trafficking is the recruitment or movement of people for the purposes of exploitation, including:
sexual exploitation; and
Modern Slavery and Human Trafficking can occur in any part of a business, in all parts of its supply chain and in its own operations, both within the UK and abroad.
The Act requires organisations who meet certain criteria to publish an annual statement outlining steps taken by the organisation to ensure slavery & human trafficking is not taken place within the organisation or in any of its supply chains.
We at Abertay University are committed to the principles of the act to protecting and respecting human rights and have a zero-tolerance approach to slavery and human trafficking in all its forms.
Under the Procurement Reform Scotland Act we already have a requirement to ensure that our supply chains are transparent. The Act requires us to set out in our strategies our approach to, and what outcomes we seek to deliver from our activity, along with the statutory duty to report annually on how we are performing in this regard.
To further identify and mitigate risk we require all new suppliers to accept the Advanced Procurement in Universities and Colleges (APUC) Supply Chain Code of Conduct (Appendix A),this ensures that our suppliers acknowledge and comply with our values.
The breadth, depth and complexity of our typical supply chain makes it challenging to manage these types of business and sustainability issues. Whilst respecting human rights in the supply chain is ultimately our supplier’s responsibility, as the customer, we expect those in our supply chain to respect our values and to adopt suitable anti-slavery and human trafficking policies and practices.
The majority of our supply chains are currently UK based and a significant amount of our spend is with UK companies that have an annual turnover of over £36m and are therefore required to publish an annual statement under the Modern Slavery Act. As such, we have assessed the risk of slavery and human trafficking in our direct suppliers as low.
To ensure that we continue to assess our existing and new supply chains, our due diligence activities will include:
Mitigate the risk of slavery and human trafficking in our supply chains through our commitment to APUC
Identify and assess potential risk areas in our supply chain by requesting the supplier to commit to the APUC Supply Chain Code of Conduct.
Ensure all suppliers of goods and services with a turnover in excess of £36m per year have published a Modern Slavery statement
Suppliers with a turnover of less that £36m and who do not publish their own statements will be required to demonstrate their commitment to the APUC Supply Chain Code of conduct with respect to their organisation and their supply chain.
Monitor potential risk areas in our supply chains and recognise the high-risk supply areas in industry and supply pools.
Our HR/People Services policies set out workplace rights at the University. We are rigorous inchecking that all new recruits have the right to work in the UK. Where it is necessary to hireagency workers or contractors, our staff are directed to specified, reliable agencies that havebeen vetted through the University’s rigorous procurement procedures as set out above. TheUniversity is accredited by the Living Wage Foundation, which certifies that all staff are paid areal living wage. Non-University contracted workers that regularly work onsite at the Universityare expected to be paid the UK living wage as defined by the Living Wage Foundation, and theUniversity evaluates suppliers’ approach to fair work practices, including the Living Wage, in linewith statutory guidance.
To ensure full awareness of, and compliance with, the Modern Slavery Act and the requirements, Abertay University will ensure this Statement is brought to the attention of all employees.
The University has a Public Interest Disclosure (Whistle-blowing) Policy to enable employees to raise concerns about malpractice including financial impropriety, criminal activity or failure to comply with legal obligations within the University. If a case of modern slavery were to be suspected, this would be fully investigated and dealt with under the policy.
Further information and guidance are available, below are links to some of that resource:
www.gov.scot/policies/human-trafficking/ - Scottish Government’s policy of Human Trafficking
www.gov.scot/publications/human-trafficking-resources/ - Scottish Government’s information on Modern Slavery and Human Trafficking – available in multiple languages
Modern Slavery Briefing – Anti-Slavery website with various resources available
www.modernslaveryhelpline.org/media/audio-visual - Video presentation to assist in the identification of Modern Slavery.
Modern Slavery Act 2015 – Modern Slavery Act 2015 Legislation
Human Trafficking and Exploitation (Scotland) Act 2015 – Human Trafficking and exploitation (Scotland) Act 2015 Legislation
A Modern Slavery helpline is available online at www.modernslaveryhelpline.org or telephone 0800 0121 700. This helpline provides advice and information regarding modern slavery 24/7.
This policy will be monitored periodically by the University to judge its effectiveness and will be updated in accordance with changes in the law.