Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking; all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
We are opposed to such abuses in our direct operations, our indirect operations and our supply chain as a whole. The University as a whole, together with support from Procurement, are committed to the adherence and implementation of the UCA Modern Slavery Statement.
As an educational establishment dedicated to the creative arts, we are committed to embedding sustainable development into our academic provision. This includes encouraging students to consider concepts of global citizenship, issues of social justice, ethics and wellbeing. We do this by including the principle in our academic plan and adopting a truly international approach to recruiting and building the student community, almost one-fifth of our students come to study with us from overseas, travelling from 91 different nations. Students are encouraged to understand the consequences of actions which could impact on a community’s sustainable future (UCA’s Strategy for Education for Sustainable Development). We are committed to improving our practices to combat slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the University’s slavery and human trafficking statement for the financial year ending 31 July 2021. It sets out the steps the University has taken to ensure that slavery and human trafficking do not take place in any part of our business or our supply chains.
UCA Organisational Structure
The University is an HE corporation and an exempt charity under the terms of the Charities Act 2011. Our core business is the advancement of Further and Higher Education and research in our specialist disciplines. The majority of our income comes from tuition fees, and we also receive some public funding directly from the Office for Students and Research England. We generate further income by providing accommodation and catering services to our students and staff.
We have campuses across Surrey and Kent plus the Institute for Creative Innovation in Xiamen, China and Maidstone Television Studios and centres with partner organisations. Our subsidiary the Open College of the Arts provides on-line courses.
Due Diligence in our Business and Supply Chains
Our supply chain is diverse and includes multinational companies to sole traders. Goods and services are procured by all departments across the University. Review of our supply chain is a continuous and expanding area. As we develop a greater understanding of Modern Slavery, we are devoting greater resources to ensure that we can identify people at risk and carry out remedial and corrective action.
We purchase goods or services from suppliers in 53 countries. Some of these countries are ranked as high-risk countries by the Walk Free Foundation’s Global Slavery Index 2018. Our interaction with high-risk countries is almost entirely related to student recruitment and the engagement of consultants.
As a university and a member of the Southern Universities Purchasing Consortium (SUPC), we can access suppliers who have been awarded places on procurement frameworks. These suppliers are subject to scrutiny to ensure that they comply with the Modern Slavery Act 2015. Even though we engage with a pre-approved supplier, we will continue to specifically ask for the suppliers’ commitment to our Modern Slavery Policy.
To raise awareness of modern slavery, new suppliers are required to provide signed confirmation of their undertaking to work alongside us in good practice. We have introduced an expanded Modern Slavery questionnaire to be completed as part of tender documentation.
All suppliers have been emailed to remind them of their responsibly and to reinforce our stand on slavery and human trafficking. Additionally, every purchase order generated is accompanied by a link to the UCA terms and conditions outlining our policy.
Suppliers of goods which are at risk of being produced through a process using forced labour will be prioritised for review on an ongoing basis. Goods that we procure that may be higher risk are:
- IT supplies
- Human Resources- the supply of staff and subcontractors
- Course materials
- Furniture, furnishings, and textiles
In keeping with our commitment to act with integrity in all our business dealings, many of our existing policies determine how the University conducts its business operations, to include sustainable, ethical, economic and social considerations in its purchase of goods and services and in the employment of staff. Relevant Policies include:
- UCA Terms and Conditions
- Anti-Bribery, Anti-Corruption and Anti-Fraud Policy
- Recruitment Policy
- Disciplinary Policy & Procedure
- Whistleblowing Policy
Following a review in 2019, UCA committed as a matter of policy to provide targeted training in Modern Slavery and human trafficking, to prevent avoidance and heighten awareness.
An online training module with targeted training, is compulsory for all new staff. Going forward, in addition to being compulsory for all new staff the module forms part of a refresher programme for staff. Staff are required to complete the current module on a biennial basis.
Plans and commitment for the future
We are committed to continually developing and maintaining transparent working relationships with our suppliers and supply chains to ensure that there is no slavery or human trafficking in our supply chains.
Our plans for 2021/22 include:
- Publicise this Statement and relevant policies
- Refresher training undertaken by staff
- Review and if appropriate implement the government’s Modern Slavery Assessment Tool
- Develop a Modern Slavery process to support staff purchasing
- Extend the use of the Modern Slavery questionnaire to higher risk suppliers in addition to those submitting tenders
- Requesting an affirmation from high-risk suppliers that they will comply with the University’s values
This Statement has been approved and published by the University’s Board of Governors following a review in November 2021. In accordance with Section 54 of the Modern Slavery Act, 2015 this statement will continue to be reviewed at least once annually.
Chair of the Board of Governors University for the Creative Arts
30 November 2021