The University is committed to combatting slavery and human trafficking in ail
its business practices. We have established a formal Anti-Slavery and Human
Trafficking Policy and Procedure which sets out our approach to this and have
ensured that this approach is embedded across related policies and procedures
and that it has a focus on our staff, supply chain and students.
Staff
The People and Culture team at the University are responsible for providing the
systems and processes to support effective recruitment, appointment and well-being of University colleagues working in partnership with managers and leaders
across the University, under the leadership of the Director of People and Culture.
They provide oversight, management and risk management across a range of
policies, processes and procedures which act to ensure that modern slavery
related risks are mitigated, including through:
- Ensuring full compliance with UK Visas and Immigration (UKVI) "right to
work" checks
- Ensuring that those directly employed by the University were
remunerated in line with the Living Wage Foundation rate in 2024/25.
- Providing routes for colleagues to raised concerns, with support to any
investigation process, with reporting as appropriate.
- Protecting those raising concerns about possible instances of slavery and
human trafficking.
The University may on occasion use agencies to provide temporary staff or may sub-contract some activities. In such cases, the suppliers of these services are required
to conduct requisite employment checks and demonstrate compliance with duties
under the Modern Slavery Act.
Supply Chain
The requirement to act ethically and safeguard human rights in the supply chain
forms part of our Procurement Policy and we manage expenditure robustly in line
with this policy. The University purchases a wide range of goods and services and we are committed to enforcing effective controls to minimise the risk of modern slavery taking place.
During procurement exercises, potential modern slavery risks are identified and a
due diligence approach adopted. Suppliers are asked to provide evidence for review
that demonstrates adherence to anti-slavery principles and practices and to the
requirements of the Modern Slavery Act. All suppliers are encouraged to register
with the NETpositive Supplier Engagement (HE) Tool, allowing the University to
access data regarding the supplier's approach in this area, including within their
supply chain, and to review and discuss their action plans.
There is added scrutiny of suppliers which provide goods or services that are deemed
to be "higher risk" in terms of the potential for modern slavery to occur. Our risk
assessment of the supplier base has identified the following categories of
expenditure as being "higher risk":
- Security Services
- Hospitality and Catering
- Information Communication and Technology Equipment and Services
- Consumables and equipment
- Cleaning
- Construction and maintenance
- Clothing
The University's use of procurement frameworks helps mitigate key modern slavery
risks and provides assurance to the University of supplier compliance. The University conducts much of this procurement via the North-West Universities Purchasing
Consortium (NWUPC), who act to collate information prior to tender award on first
and second tier supply chain and then work with suppliers post contract to
encourage them to look beyond their statements and conduct robust analysis of their supply chains to identify areas of risk and the actions they are taking in mitigation.
Students
The University ensures that modern slavery risks to our students are considered as
part of our wider approach to the Safeguarding, with a specific focus on this area
within our Safeguarding and Prevent Policy. In order to ensure an ongoing focus on
such risks, the University's operational lead for modern slavery is a member of the
Safeguarding Steering Group.