Modern Day Slavery and Human Trafficking Statement

Introduction

Modern slavery is an overarching term to describe all forms of contemporary slavery including human trafficking, slavery, servitude, forced, bonded and child labour, all of which deprive a person of their liberty so they can be exploited by another for personal or commercial gain.

The University of Southampton is committed to improving its practices to combat modern slavery and human trafficking. This statement sets out steps taken in response to the Modern Slavery Act 2015 (the “Act”), together with future plans.

An ethically and socially responsible university

We are a world-class University dedicated to excellence across Education, Research, and Knowledge Exchange and Enterprise – our triple helix.  People are at the heart of everything we do and the impact we make on a local to international scale. We are a global University with a community drawn from over 150 countries. Our commitment to being an ethically and socially responsible University guides our policies and processes.  

Further information about the values that drive us are contained in our Strategy ( Our strategy | University of Southampton).  Delivery of the Strategy is supported by a sustainability strategic plan, developed in partnership with the Students’ Union.  This commits us to adapting our triple helix to advance the United Nations’ Sustainable Development Goals. 

Overview

The following principles underpin our response to the Act:

  • Our recruitment policies and processes are designed to ensure all employees are legally entitled to work in the UK.
  • Our employment procedures are designed to uphold an inclusive working environment that safeguards employees from abuse or coercion.
  • Commitment to awareness raising and staff training designed to both identify the risk of modern slavery and how to report suspected cases.
  • Commitment to assess and monitor areas of potential risk in our business and supply chains to reduce the risk of modern slavery and human trafficking.

Highlighted actions

  • We promote awareness of the risk of modern slavery and human trafficking through our supply chain.
  • We have strengthened our approach to responsible procurement by developing an internal framework that helps us to understand effective means of embedding responsible procurement in our tenders and contract management activity.
  • We have segmented our supply chain by category to understand high risk areas. This results in increased focus for greatest impact in tendering and contract management activity.
  • Reports can be made anonymously via Report+Support for any form of bullying, harassment, discrimination or abuse, allowing individuals to report incidents they experience or witness in a secure and confidential manner.    
  • We have a track record of over a decade of meeting or exceeding the  Living Wage Foundation hourly rate.  
  • Introduced a network of ‘Super Recruiters’ who can support, influence and role model inclusive recruitment practice throughout the recruitment process, strengthening the opportunities of increasing the diversity of the workforce and sharing good practice across the University.
  • A comprehensive research integrity framework ensures research is conducted according to appropriate ethical, legal, and professional frameworks, obligations, and standards.
  • Our Treasury Management Policy sets out the measures we expect to be in place before we would work with a financial institution.  These state that we will exclude investments which involve modern slavery.  This is tested and challenged with our fund managers on a regular basis to ensure we continue to invest in an ethical way which aligns with the values of the University. 

Employment policy and practices

We embed our principles through the following people-focused policies and processes:

  • Robust recruitment practices that allow us to attract, assess, select, and employ the right candidate. These include:
    • Holding face-to-face interviews, assessment centres or live video interviewing, which provide assurance that individuals have freely chosen to attend.
    • Carrying out a range of pre-employment checks that include the right to work, to ensure the individual has the right to live and work in the UK; employment references; occupational health questionnaire; where relevant proof of qualification, training, registration or licence with a professional organisation or membership body; and criminal record (DBS) or other Government security clearance.
    • Provision of a written contract which sets out the terms and conditions of employment including sick pay, holiday, and any other benefits the employee may be entitled to.
    • Salary payments which are only paid into a bank account (or joint bank account) in the name of the employee.
  • UniWorkforce administer casual work assignments for the University and ensure workers have the right to work in the UK, are set up for payment through the payroll, and are paid equitably.
  • Where we use external recruitment agencies and flexi-job apprenticeship suppliers, these are subject to our procurement due diligence processes.
  • We provide managers with a range of guidance on the recruitment process and the use of UniWorkforce and external temporary agencies. Training is available on recruitment and selection with different options to cover those who are new to recruitment at the University, or have some recruitment experience, or for experienced recruiters as a refresher.
  • We have a set of 'Southampton Behaviours' which outline the responsibility we each have in working collaboratively to achieve our strategy. They are about developing trust, respect and compassion, supporting and encouraging each other, and striving to achieve the best outcome for all concerned.
  • We have a Grievance Procedure which sets out our approach to dealing with any concerns, conflicts, or complaints any employee may wish to raise during their employment.
  • We have a Whistleblowing policy through which concerns about Modern Slavery can be raised.
  • A range of support services is available to our staff during their employment. These include: 
    • Report + Support - for reporting any form of bullying, harassment, discrimination, or abuse. Reports can be made as a named person or anonymously.
    • Harassment contacts - trained to provide confidential support to  staff who feel bullied or harassed.
    • Employee Assistance Programme (EAP) - support to cope with life's difficulties and challenges available 24 hours a day, 365 days a year.
    • Occupational Health - provide advice above an individual's health to better support them during their employment.
    • Equality Staff Networks - to represent, support and engage members who share a similar background, characteristic or common cause.
    • Faith and Reflection Centre - the chaplains offer an independent listening service to people of all faiths and none.
  • The following policies support our commitment to protecting and respecting human rights and an inclusive and supportive working environment, and ensure we are conducting business in an ethical and transparent manner:
    • Ethics Policy
    • Inclusion and Respectful Behavior Policy
    • Whistleblowing Policy
    • Anti-corruption, Fraud & Bribery Policy
    • Conflict of Interest Policy
    • Health and Safety Policy 

Procurement and the supply chain

We are committed to ensuring that our supply chains impose the same high standards and are aware of our policies and practices.  

The University procures works, goods, and services in excess of £200m each year. We work with more than 5,500 suppliers based in the UK and internationally.  

We are committed to acting ethically and with integrity in our business dealings, combatting modern slavery and human trafficking within our supply chain. Understanding our diverse and complex supply chain is key to identifying and mitigating risk at various points in the procurement lifecycle; we aim to maintain this risk oversight to enforce effective controls.  

Actions to embed our principles fall under the headings set out below.

Understanding our supply chains

We have categorised our supply chain using a category commodity code approach and through strategic review.  Our category plans identify high risk areas, enabling a focused approach to tendering and contract management activity in these areas. Scrutiny is applied through tendering and contract management processes, applying due diligence at key points. 

Our supply chain includes:

  • estates goods, services and construction works
  • laboratory equipment and consumables
  • IT equipment and services
  • professional services
  • student services

Due diligence

Our tender documents include modern slavery checks ensuring their compliance with the Act. This includes grounds for rejection where there have been convictions under the Act. Where appropriate, and in high-risk areas, our tenders include additional questions and evaluation criteria relating to identifying and mitigating modern slavery risks. For example, tenderers have been asked to:  

  • Describe measures taken to ensure compliance with labour standards, human rights and responsible sourcing practices,   
  • Describe how their sourcing and supply chain strategy will ensure that appropriate and comprehensive systems are in place to minimise or avoid potential ethical and social risks on behalf of the University,  
  •  Provide examples of any policies, certification or initiatives they have in place to address these concerns. and  
  •  Demonstrate how these policies are effectively communicated and enforced throughout the various tiers of their supply chain, including subcontractors and sub-tier suppliers. 

Our standard terms and conditions for the supply of goods and services, and purchase order terms, require all suppliers to comply with relevant legislation and provide termination in the event of a breach for non-compliance.

We have introduced an internal responsible procurement framework which facilitates the tracking of procurement activity and contract management.

Our contract management review monitoring ensures strategic suppliers have anti-Modern Slavery policies in place.  Regular supplier review meetings are undertaken for critical contracts where discussions relating to the prevention of Modern Slavery in supply chains take place. Supplier management information is sent at regular intervals for these critical contracts for scrutiny by the allocated Contract Manager. 

ICT hardware such as desktops, laptops and peripherals are purchased through the London University Purchasing Consortia (LUPC) framework agreement which provides reassurance that high risk supply chains are monitored by Electronics Watch. 

Electronics Watch are an independent monitoring organisation which monitors working conditions in factories producing Information and Communication Technology (ICT) goods bought by public sector members. Suppliers provide details of the factories in which the ICT equipment bought by the University are produced, and Electronics Watch works with civil society organisations in the countries where the factories are located to monitor working conditions. When issues are detected, our Contract Management Team and LUPC raise them with suppliers during contract management meetings.   

Through our Southern Universities Procurement Consortia (SUPC) membership, we are an affiliate member of Electronics Watch. We select and utilise sector and other national framework agreements, where we have assurance that modern slavery considerations have been incorporated into award criteria. 

Training and raising awareness

Procurement and contract management team members undertake relevant Modern Slavery training, including sector-specific online modules and regular internal development sessions on responsible procurement.

We participate in the UK Universities Purchasing Consortia (UKUPC) and other sector Responsible Procurement groups, deepening our understanding and sharing best practice across the sector.

Active Bystander workshops support staff to challenge poor behaviours.

Future plans: 2025 and beyond

Additional plans to combat modern slavery include:

  • Continue to evolve our understanding of our complex and often-changing supply chains by refining our categorisation and scanning for potential high-risk areas.
  • Expand the coverage of our responsible procurement framework to capture and track activity through the tendering and contract management phases of key supplier relationships.
  • Continue to engage with the UKUPC and other Responsible Procurement groups, to keep abreast of best practice and work collaboratively as a sector to drive change.
  • Increase awareness of the risks of modern slavery in supply chains with a wider University audience, via procurement internal webpages and communication channels.
  • Deploy a Supplier Code of Conduct which sets out our expectations for suppliers working with the University.
  • Develop and deploy a bank of Responsible Procurement Questions and Key Performance Indicators to be included in relevant tenders. 
  • Explore new opportunities for action with our newly established Sustainability and Resilience Institute.
  • Delivery of a strategic major project called Reducing Casualisation to reduce the reliance on casual contracts and promote fair employment practices in the University. For this project, casual contracts are any contract which is not permanent, including fixed-term contracts, hourly-paid lecturers, and other casual workers engaged via UniWorkforce.
  • Raising awareness of the Act through our 'Super Recruiter' network, and our recruitment and selection training.
  • Strengthening the message within the whistleblowing policy, such that it provides a mechanism for reporting potential concerns about modern day slavery and human trafficking.

 

This statement was approved by the University's Council on 19 November 2024

Signed by : Professor Mark E. Smith
President and Vice-Chancellor, University of Southampton