Manchester Metropolitan University

Modern Slavery and Human Trafficking Annual Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Manchester Metropolitan University’s slavery and human trafficking statement for the financial year ending 31/07/2016. This statement sets out the steps that the University has taken and is intending to take to ensure that slavery and human trafficking is not present in the University’s supply chains or any part of the University’s business.

Introduction

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 one person's liberty by another for personal or commercial gain.

At Manchester Metropolitan University, we are committed to combatting modern slavery.

Organisational structure

Manchester Metropolitan University is one of the largest campus-based universities in the UK with a total student population of over 36,000. The central Manchester campus is situated close to Manchester city centre and the second campus is based in Cheshire, 35 miles from Manchester. The University is arranged into eight faculties, each providing speciality learning, teaching and research hubs for undergraduate, postgraduate and professional development. Our annual turnover for the financial year 2015-2016 was £298m.

Our policies/documents on slavery and human trafficking

We are committed to ensuring that there is no modern slavery in our supply chains or in any part of our organisation.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free, we have put in place a designated Modern Slavery and Human Trafficking Policy. Our Modern Slavery and Human Trafficking Policy demonstrates our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our supply chains or any part of the University’s business. We have also incorporated the Modern Slavery Act 2015 into our purchasing procedures and into our Sustainable and Ethical Procurement Policy.

Our standard Contract for Services for services provided to the University now includes reference to suppliers’ compliance with the Modern Slavery Act 2015.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our organisation, we provide training to our staff as part of ethical procurement. Training has been delivered to the University’s Human Resources, Legal and Procurement teams. The training comprised information on modern slavery, University obligations and the Annual Statement. We also encourage our suppliers to provide training to their staff, suppliers and providers through ongoing contract management discussions via the University’s supplier engagement tool.

Further steps taken

To date we have:

Reviewed our supply chain and identified general potential areas of risk including:

1. Construction

The construction industry has been associated with the exploitation of vulnerable migrants including bonded labour, delayed wages, poor working and living conditions, withholding of passports and limitations of movement.  We have signed up to the North West Construction Hub (NWCH) and their framework is being used for the construction of the University’s new Art and Media Building. The NWCH captures data across various KPIs including; local labour, fair payment, social value, health and safety and supply chain value. These KPIs are regularly reviewed and reported to the NWCH Board and Framework Management Group (FMG). We are provided with access to the KPI dashboard and can review data against the NWCH benchmarks.  This helps the University to ensure that the contractors in place for its construction projects are modern slavery free. In addition, any contracts that the University enters into with a contractor or consultants to carry out works or provide services will contain specific provisions requiring compliance with the Modern Slavery Act 2015.

2. IT products

Forced labour is recognised as high risk in the electronics industry throughout developing countries. They include inadequate laws and regulations, weak enforcement of fundamental labour rights, and high levels of poverty. Electronics Watch is an independent monitoring organisation that assists public sector buyers to meet their responsibility to protect the human rights of electronics workers in their global supply chains. The London Universities Purchasing Consortium (LUPC) is affiliated with Electronics Watch and does this on behalf of all English Consortia (including the NWUPC) under the Purchasing England Ltd (PEL) banner. We buy most of our IT products from the North Western Universities Purchasing Consortium (NWUPC). Electronics Watch serves as the “eyes and ears on the ground” for affiliates, working with trained and qualified local civil society organisations who undertake continuous intelligence gathering through trusted relationships with workers.  The University is comfortable that this protects against the risk of modern slavery in our IT supply chains.

3. Provision of food

Manchester Metropolitan University is proud to be an official Fairtrade University. The elimination of modern slavery is covered within the Fairtrade Produced Standards and Fairtrade Trader Standards.  Everyone who buys, sells or processes Fairtrade certified products from the raw commodity to packaging must comply with these standards. The University’s Fairtrade Steering Group manages Fairtrade accreditation at the University and the Union. The seafood industry is also well known as being a high-risk area in terms of modern slavery. All of the University’s seafood products are Marine Stewardship Council (MSC) certified. MSC is the leading marine eco labelling charity and condemns use of unethical labour practices including forced labour, trafficking and other forms of modern slavery. The MSC has agreed to include a clear policy on the issue of forced labour within the requirements of MSC certification. Companies which have been prosecuted for modern slavery violations will be ineligible for MSC certification. We currently use local suppliers for most of our fresh produce along with meat and dairy. We buy sustainable produce from local farms, and members of our catering team regularly visit the farmers who provide our salad and vegetables to ensure our standards are met.

Supplier engagement and contract management

The University has subscribed to a supplier engagement tool developed by NETpositive Futures. The tool enables suppliers to the Higher Education Sector to create a simple, free sustainability action plan tailored to their business, where the plans form part of ongoing contract management discussions. The tool addresses issues raised by the Modern Slavery Act 2015. Part of the action plans includes developing a code of conduct, which prohibits the use of forced or trafficked labour, engaging with their suppliers on modern slavery, training their staff on modern slavery and publishing a “Modern Slavery Act Transparency Statement”. This has highlighted the importance of the issue with many of our suppliers. The University is actively encouraging more suppliers to complete an action plan, which addresses Modern Slavery.

Additionally, a supplier risk register has been set up in Microsoft Excel, which looks at high value spend split by commodity groups. The suppliers were listed and assigned risk scores (3 being the highest and 1 being the lowest), including scoring for modern slavery. This has provided the University with valuable information on high-risk suppliers. These suppliers will be encouraged to complete the action plan from the tool.

The University’s internal business

The University has also considered the risks of modern slavery occurring within the University.

The specific areas considered have been:

The University is comfortable that it has a robust system in place with regard to internships provided, ensuring that those taking part in University internships are adequately remunerated and treated within the terms of the Modern Slavery Act 2015.

In respect of Agency Workers, the University is in the process of reviewing its approach to recruiting agency workers to avoid the risk of modern slavery occurring.

Future plans

Following a review of the effectiveness of the steps we have taken this year to highlight modern slavery or human trafficking in our supply chains, we intend to take the further steps.  Procurement staff will:

This Statement has been approved by the Director of Finance, John Cunningham on the 30th January 2017 following approval from our Board of Governors on the 25th October 2016.