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Modern Slavery and Human Trafficking Statement


This statement, made pursuant to section 54 (1) of the Modern Slavery Act 2015, constitutes the University’s Modern Slavery and Human Trafficking Statement setting out the steps that Staffordshire University has taken to combat modern slavery in our supply chain. We are committed to improving our practices to combat slavery and human trafficking.

Organisational structure

Staffordshire University’s core business is teaching and research in the Higher Education sector. It has a student population of approximately 10,000 in a wide range of subject areas, comprising six (6) academic schools supported by professional services. The University employs around 1,300 staff with a mix of full time and part time academic, administrative, technical and support staff.

The University has an annual turnover of £120 million (2018/19) of which c£25 million is spent on goods and services to support the running of the University. There is a planned capital expenditure of c£37m over the coming years to improve student facilities. The University has a centralised procurement and contracting function supporting procurement activity, with purchasing devolved down to individual schools and functions.

Our supply chains

Like most universities, we purchase goods, services and works from a wide range of suppliers and from a number of categories which have been identified as ‘high risk’ in terms of the potential for slavery, servitude, forced and compulsory labour, and human trafficking. This is referred to as ‘Modern Slavery’ in this statement. These include, but are not limited, to:

  • Security Services
  • Hospitality and Catering
  • Information Communication and Technology Equipment and Services (IT)
  • Cleaning
  • Construction
  • Clothing.

Our initial targets in relation to Modern Slavery were as follows:

  • To ensure our supply chain has been made aware of our policy regarding the Modern Slavery Act
  • To promote best practice on approaches to Modern Slavery awareness throughout our supply chains
  • To report on non‐compliance identified within our supply chain and actions taken

Many of our suppliers in these higher‐risk categories have committed to the Base Code of the Ethical Trading Initiative (ETI) and the UK Universities Purchasing Consortia are working to persuade the remaining suppliers in these categories to join them. The ETI Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice.

Our policies and processes on slavery and human trafficking

We have embedded our commitment to compliance with the Modern Slavery Act within our Sustainable Procurement Policy. This policy provides guidance on how we deliver all our procurement activity.

We have embedded consideration of the Modern Slavery Act in our procurement process from the Standard Selection Questionnaire and Invitation to Tender documents through to contract management. We request Modern Slavery statements for organisations over the £36 million threshold and ask how the company addresses compliance to the Modern Slavery Act. For expenditure in high risk categories we also ask supplementary questions to ensure compliance.

When purchasing from established frameworks, as a Member Institution of the North Western Universities Purchasing Consortium (NWUPC), we can be assured that Modern Slavery compliance issues are covered by our collaborative partner on our behalf.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. Any supplier or potential supplier who does not adhere to these values or is found not to be compliant will be suspended and removed from the University supplier list and will not be considered for future supply unless and until they are able to demonstrate full compliance with the requirements of the Modern Slavery Act.

Supplier engagement

We have contacted suppliers with whom we undertake major expenditure to understand:

  • Which of our suppliers are aware of the Modern Slavery Act
  • Which of our suppliers consider Modern Slavery to be an issue for their business
  • Which of our suppliers are taking proactive action regarding the Modern Slavery Act and the progress they are making

This approach and the evidence gathered will assist us in targeting our activities to those suppliers and supply chains who are either not aware that Modern Slavery is an issue for their business or are not taking a proactive approach within their supply chains. We consider this activity a sensible approach to set our baseline for engagement with our suppliers.

Action completed

In our Slavery and Human Trafficking Statement we state that we are committed to understanding our supply chain and using a data driven approach for our future engagement on Modern Slavery with our suppliers.

We have invited our suppliers to engage with Modern Slavery through a tool developed with the public sector in mind (NetPositive Futures, “Suppler Engagement Tool”) which supports their understanding of a range of environmental, social and economic issues. The tool allows us to understand the progress of our suppliers on several key issues including Modern Slavery and supports the companies in developing an action plan to address key sustainability issues. The data we have gathered provides us with a starting point to focus and measure the impact of engagement with our supply chain on this critical issue.

Since the introduction of the Modern Slavery Act (2015) organisations with a turnover of over £36 million have been busy producing statements outlining their response to the Act. Although only larger organisations are currently obliged to produce statements, we believe that SMEs will be expected to consider their processes as scrutiny of supply chains intensifies. Staffordshire University is committed to proactive engagement with SMEs in our supply chain and this issue can be an opportunity to support good practice at the same time as reducing risk. The Supplier Engagement Tool is already helping us to establish baselines, gather evidence and demonstrate practical examples of how different businesses are responding to the challenges presented by the Modern Slavery Act.

Next steps

The procurement team will use this baseline to develop deeper supplier engagement relating to Modern Slavery and Human Trafficking as follows:

  • Continue to embed Modern Slavery considerations within the procurement process and practice
  • Explore the data we have available in more detail to ensure we are targeting high risk suppliers
  • Work with peers across the sector to share and learn on the best practices in tackling Modern Slavery



Sally McGill
Chief Financial Officer
2nd December 2019