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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 Five (5) 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 £123 million (2019/20) of which c£37 million is spent on goods and services to support the running of the University. There is a planned capital expenditure of c£58m 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

Our supply chain includes a large number of diverse suppliers, including suppliers of goods and services that directly support research and teaching activity, for example, for the supply of student computer equipment, library services including books and online services, and suppliers of goods and services not directly related to these activities such as estate maintenance. Our requirements are from several categories which have been identified as ‘high risk’ in terms of the potential for slavery, servitude, forced and compulsory labour, and human trafficking. 

 These include, but are not limited, to:

  • Hospitality and Catering
  • Information Communication and Technology Equipment and Services (IT)
  • 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.

As a user of a variety of external framework contracts we continue to work closely with two locally based procurement consortia, the North Western Universities Purchasing Consortium (NWUPC) and TUCO (The University Caterers Organisation), to manage risks through contract management processes.

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.

We have embedded our commitment to all members of staff within University Policies that include Equality, Diversity, Health and Wellbeing and Bullying and Harassment.

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

100% of the Top 100 suppliers with whom we undertake a high proportion of our annual expenditure in our supply chain have been made aware by Staffordshire University via NetPositive Futures that modern slavery is a consideration for their business

30% of our Top 100 suppliers have acknowledged modern slavery is a consideration for their business

15% of our Top 100 suppliers have committed to act, have ongoing actions or completed actions that address modern slavery in their business.

The Head of Procurement has presented to the University Sustainability Group on the Modern Slavery Act and has presented to the University Connected Community Group the GLAA ‘Horse Trading’ video.

Key procurement staff have completed the updated HEPA training module ‘Guide to Modern Slavery’.

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
  • Continue to make presentations to colleagues explaining the importance of Modern Slavery and the role the University may play
  • 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 and Deputy Chief Executive
1 December 2020