MODERN SLAVERY STATEMENT
This is the Modern Slavery Statement for the University of the West of Scotland for the financial year ending 31st July 2022. It is made pursuant to section 54 of the Modern Slavery Act 2015.
OUR ORGANISATION
The University of the West of Scotland (“UWS”) is a “body corporate” under the terms of a statutory instrument. UWS’ constitutional basis is contained within the Order of Council 2019. Our governing body is the University Court.
UWS is organised into four academic Schools for learning, teaching and research spread across four campuses in the west of Scotland and one in London. We employ approximately 1435 members of staff.
We have a zero tolerance approach to modern slavery and human trafficking. This Statement sets out the measures that we have taken to prevent these practices from taking place in our own organisation and in our supply chains.
Our Supply Chains
We purchase a wide range of goods and services from suppliers including:
- IT equipment and services
- Professional services
- Residential services
- Estates and facilities management goods and services
- Food and catering supplies
- Books and printing
- Laboratory supplies
- Furniture and stationery
- Waste and recycling services
IDENTIFYING AND MANAGING RISK IN OUR ORGANISATION
Our Staff
Our commitment to employment rights is set out in our People and Organisational Development Policy Statement.
Rigorous right to work checks are carried out for all new members of staff to ensure that they are legally entitled work in the UK.
We pay all UWS staff and contractors engaged directly by the University at least the Living Wage, as set by the Living Wage Foundation.
When it is necessary to fill employment vacancies using recruitment agencies, our Procurement Team oversee the procurement process and identify the appropriate Framework Agreement entered into by APUC, the Scottish Government or other UK procurement consortia. This ensures that the University only uses recruitment agencies who have been through a rigorous tender process.
Training
We inform staff of our zero-tolerance approach to slavery and human trafficking by circulating our Modern Slavery Statement in the UWS e-bulletin twice a year. To promote understanding and awareness, the Legal Services Team ensure that mandatory training on modern slavery is delivered to higher risk departments. Further training is planned for these departments in the next financial year. Optional in-person or virtual training on modern slavery is available to all staff on request. The online ‘Working with the Modern Slavery Act’ module is also available to all staff.
Procurement Regulations & Sustainability training is available through APUC (Advanced Procurement for Universities and Colleges) and has been completed by all members of the Procurement Team. All members of the Procurement Team have also completed the HEPA training on Protecting Human Rights in the Supply Chain.
Donations
Before accepting any charitable donations, we carry out a number of checks to ensure that the funds do not come from unethical sources. The donation will then be subject to approval by our Donations Group, Vice Chancellor’s Executive Group or the University Court depending on its monetary value. This Procedure was reviewed and updated in July 2022.
Reporting Concerns
The University adheres to the Public Interest Disclosure Act 1998 and encourages all staff to report possible wrongdoing or malpractice within the University. The process for making a disclosure is set out in our Procedures for Raising Concerns.
We also launched the Report and Support Tool to all staff and students in 2021. This online platform enables individuals to report issues of concern either anonymously or by identifying themselves. They can also seek support through the tool from both internal and external services if they are experiencing difficulties themselves.
IDENTIFYING AND MANAGING RISK IN OUR SUPPLY CHAINS
APUC
We procure goods and services of the qualifying value through the APUC (Advanced Procurement for Universities and Colleges) Ltd Framework. APUC requires all suppliers to adopt their Supply Chain Code of Conduct, which confirms that it does not use forced, involuntary or underage labour, provides suitable working conditions and treats employees fairly.
Scottish Government Sustainable Public Procurement Prioritisation Tool
We use the Sustainable Public Procurement Prioritisation Tool which supports organisations to consider the social, environmental and economic of future purchases.
Modern Slavery Compliance Statement
New suppliers are required to sign up to our Modern Slavery Compliance Statement, setting out their commitment to eradicating modern slavery. The Statement was developed by the Procurement and Legal Services Teams and introduced in the last financial year. It is included in all invitations to tender, new supplier forms and non-competitive actions.
In October 2022, the Procurement Team selected a sample of our existing suppliers and assessed their compliance with the Modern Slavery Act. Suppliers were identified through the Spikes Cavell Annual Spend Report and their Modern Slavery Statements were reviewed against the ‘Modern Slavery Checker’ created by the Chartered Institute of Procurement and Supply. This Checker helps organisation to ensure that their suppliers are taking the necessary steps to make their supply chain more transparent. A similar review will take place on an annual basis.
Electronics Watch
We are a member of Electronics Watch, an organisation that works to ensure good working conditions in factories producing Information and Communication Technology (ICT) goods bought by public sector members across Europe.
TUCO
Our Catering and Events Team are committed to sustainable procurement and working with ethical suppliers. To help to achieve this aim, the Team conduct their procurement through TUCO (The University Caterers Organisation) Ltd. Through the TUCO framework, the University has recently introduced new suppliers, who align with our values, into the catering outlets on our campuses.
Coffee Conscience
All coffee sold in UWS’ catering outlets is fair trade and purchased through Coffee Conscience who source ethical produce and support community initiatives globally.
KEY PERFORMANCE INDICATORS
(since the introduction of the Modern Slavery Act 2015 unless otherwise stated)
- No concerns about modern slavery or human trafficking have been reported to the University directly;
- No concerns about modern slavery or human trafficking have been reported through the Report and Support Tool;
- 100% of the Procurement Team have received internal training from the Legal Services team on compliance with the Modern Slavery Act;
- 100% of the Procurement Team have received external training on the Modern Slavery Act (through APUC and HEPA as detailed above);
- 100% of UWS staff and contractors engaged directly by the University are paid at least the Living Wage, as set by the Living Wage Foundation;
- 100% of contracts tendered through the University’s Procurement Team were entered into using our standard Terms and Conditions in the financial year ending 31 July 2022. From 1 November 2022, the Procurement Team have required all new suppliers to sign up to our Modern Slavery Compliance Statement and compliance with this will be set as a Key Performance Indicator in the next Modern Slavery Statement.
This Statement was approved by the University Court on 29 November 2022 and signed below by the University’s Principal and Vice-Chancellor.