Modern Slavery Statement
Structure and governance
Slavery and Human Trafficking Statement
The University of Portsmouth is committed to combatting slavery and human trafficking in its supply chains. The University has previously made two annual statements under the Modern Slavery Act 2015 in January 2017 and January 2018. This third annual statement provides an update on the actions proposed in its previous annual statement and sets out the steps that the University plans to take over the coming twelve months to ensure, as far as possible, that slavery and human trafficking are not taking place in any part of our organisation or its supply chains.
The University’s Structure
The core business of the University is teaching, research and innovation, undertaken by five academic faculties supported by professional services. The University has approximately 24,000 students and 2,700 staff. The University is supported by a centralised procurement and contracting function located within the Finance Department with transactional purchasing devolved to individual faculties and services.
Procurement in the University of Portsmouth
The University’s Procurement Team currently manages a spend of approximately £70 million per annum. The diverse nature of the spend involves dealing with a large number of suppliers, their sub-contractors and their supply chains.
The University’s supplier base ranges from cutting edge scientific/engineering equipment to everyday stationery and furniture. The spend breaks down into the following categories:
- Audio Visuals
- Cleaning and Facilities Management Services
- Communications and Marketing
- Computing – ICT Equipment and Services
- Food and Beverage
- Office Supplies (Stationery)
Update on Activities
In the 2018 Modern Slavery Statement the University said it would aim to achieve the following:
- Analyse the information we receive from supplier modern slavery surveys to conduct a more thorough assessment of where the key areas of risk lie for the University and produce a plan of the further work required, including further supplier engagement and audits where required.
- Work with suppliers who do not have acceptable policies and procedures in place to address the risks of modern slavery. Where necessary, the University will terminate contracts with suppliers who do not meet the University’s ethical standards in this area.
- Develop and implement an Anti-Slavery and Human Trafficking Policy.
- Undertake an exercise to establish how we will factor legal and fair labour costs into sourcing costs to ensure we avoid the suppliers that use slave and bonded labour.
In the period since the last Modern Slavery Statement, the University’s top 25 suppliers (by spend) were sent questionnaires designed by the University to gain more insight into their stance, processes and procedures on modern slavery. The responses from the questionnaires were analysed together with their corresponding modern slavery statements and in general, from a desktop analysis, demonstrated that the suppliers surveyed had developed appropriate processes and procedures to combat modern slavery within their organisations. Where suppliers’ returns demonstrated gaps or weakness these have been followed up with suppliers to assess what the reasons are for the deficiencies and how these will be rectified.
The return rate of questionnaires was lower than we had hoped for with seven suppliers not returning the questionnaire, meaning it was less easy to detect trends or key risk areas than anticipated. We are also aware that the suppliers surveyed tended to be larger and more well established organisations which would necessarily have more developed processes in this area. The actions set for the next 12 months include steps which will address this and produce a fuller data set for future analysis.
The Procurement Team has considered the most effective method to factor fair labour costs into sourcing costs to ensure we avoid the suppliers that use slave and bonded labour. Going forward, greater granularity and transparency will be required from bidders on labour costs. Mechanisms will be put in place within the procurement process to flag exceptionally low cost tender responses which may indicate the use of forced labour.
An Anti-Slavery and Human Trafficking Policy has been developed and, subject to the University’s internal approvals, will be in place by the end of 2018.
We have made good progress against last years’ objectives and are gaining valuable insight into the University’s supply base and its approach to this key issue. Moving into our third year of compliance with the Modern Slavery Act, we are gaining a better understanding of the information required to inform our future actions in this area and the objectives for the next 12 months are designed to support our continued development in this area.
Activities for the Next 12 months
Over the next 12 months the University will:
- Follow up with suppliers who have not responded to the University’s modern slavery questionnaire.
- Issue a further 20 supplier questionnaires which capture significant new suppliers engaged since the last modern slavery statement was published.
- Conduct full analysis of the returned questionnaire and identify any themes or key risk areas.
- Develop a University modern slavery audit template document and carry out at least one pilot physical supplier audit which has modern slavery and human trafficking as its central theme.
Chair, Board of Governors
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the University’s slavery and human trafficking statement for the financial year ending 31 July 2018.