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 for personal or commercial gain.
UCA is committed to proactively preventing modern slavery in both our direct suppliers and in our supply chain as a whole.
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 many 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 2022. 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 a Higher Education 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. Most of our income comes from tuition fees, 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 as well as centres in partner organisations.
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. We continue to review our supply chain on an ongoing basis, both to ensure continuing best value and compliance with our policies, including the prevention of Modern Slavery.
We purchase goods or services from suppliers in dozens of Countries. Some of these countries are ranked as high-risk countries by the Walk Free Foundation’s Global Slavery Index 2018 and are of particular concern, although Modern Slavery can happen in any Country.
We purchase many of our services through procurement frameworks, as part of these frameworks these suppliers will already have been vetted, however we will continue to ensure their compliance with our policies.
To raise awareness of modern slavery, new suppliers are required to provide signed confirmation of their undertaking to work alongside us in good practice and compliance with our policies. Additionally, every purchase order generated is accompanied by a link to the UCA terms and conditions outlining our policy.
All suppliers with which we spent over £25k were emailed in 2022 to remind them of our requirements along with a link to this statement. In addition, we provided information on a confidential whistleblowing service they can use if they have any concerns about people at risk.
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
- 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
UCA committed as a matter of policy to provide targeted training in Modern Slavery and human trafficking, to aid compliance 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 2022/23 include:
- To review our procurement policy to ensure that the prevention of modern slavery is at the heart of our procurement process.
- To investigate the feasibility of purchasing an electronic supplier monitoring system.
- To review our induction procedure for staff on the prevention of Modern Slavery.
- To examine the feasibility of becoming members of schemes such as Fair Trade and Electronics Watch to help address our purchases in high-risk areas.
This Statement has been approved and published by the University’s Board of Governors following a review in November 2022. In accordance with Section 54 of the Modern Slavery Act, 2015 this statement will continue to be reviewed at least annually.
Chair of the Board of Governors University for the Creative Arts
30 November 2022