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 31/07/2017. 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.
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 combating modern slavery.
Manchester Metropolitan University is one of the largest campus-based universities in the UK with a total student population of over 37,000 and around 4,000 staff. 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 six faculties, each providing speciality learning, teaching and research hubs for undergraduate, postgraduate and professional development. Our annual turnover for the financial year 2016-2017 was £312.6m
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 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 is currently undergoing review but includes reference to suppliers’ compliance with the Modern Slavery Act 2015 and our purchase order terms are undergoing similar review.
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 and also to key members of IT. 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.
As part of our review of procedures we have:
Reviewed our supply chain and identified general potential areas of risk including:
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 has been 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, there are procedure to ensure that 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.
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. The North Western Universities Purchasing Consortium (NWUPC) and London Universities Purchasing Consortium (LUPC) are just two members of a purchasing consortia operating under the Purchasing England Ltd (PEL) banner to share expertise and best practice. LUPC is a founding member of Electronics Watch, which 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. We buy many of our IT products from the North Western Universities Purchasing Consortium (NWUPC) and Crown Commercial Services frameworks and through the links with LUPC and PEL are able to benefit from the best practice identified by Electronics Watch. 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. In addition, the University’s open procurement process includes assessment of potential suppliers’ compliance with the Modern Slavery Act 2015.
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 includes 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. In addition, the University is an active member of The University Catering Organisation (TUCO) and uses TUCO frameworks as its primary purchasing route, including to buy local fresh produce, meat and dairy. As part of the due diligence process to admit suppliers to these frameworks, TUCO requests copies of Modern Slavery Statements from all relevant suppliers and acknowledgement of the legislation from SME’s.
The University subscribes 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. 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 will actively encourage more suppliers to complete an action plan, which addresses Modern Slavery.
The University has also considered the risks of modern slavery occurring within the University.
The specific areas considered have been:
- Agency workers
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.
In respect of Agency Workers, the University is currently reviewing a number of framework options and its approach to recruiting agency workers to avoid the risk of modern slavery occurring.
Each year we plan to reassess the effectiveness of the steps we have taken in the previous year to highlight modern slavery or human trafficking in our supply chains. In the coming year Procurement staff will:
This statement has been approved by the Director of Finance and was endorsed by the Board of Governors at a meeting on 24 November 2017.