In accordance with Section 54 of the Modern Slavery Act 2015, the University is required to prepare a slavery and human trafficking statement for each financial year, setting out what steps it has taken to ensure modern slavery is not taking place in its business or supply chains.
The University’s slavery and human trafficking statement for the financial year ended 31 July 2020 is below.
Slavery and human trafficking statement for the financial year ended 31 July 2020
(issued pursuant to section 54 of the Modern Slavery Act 2015)
The University is committed to ensuring that there is no slavery or human trafficking in our supply chains or any part of our business. The processes set out below reflect the University’s commitment to acting ethically and with integrity across the organisation.
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 ended 31 July 2020.
This statement was approved by the General Purposes Committee of Council on 19 October 2020.
The University of Oxford is a civil corporation established under common law, which was formally incorporated by the Act for Incorporation of the Universities of Oxford and Cambridge 1571 under the name of 'The Chancellor Masters and Scholars of the University of Oxford'. The University of Oxford is an exempt charity under the Charities Act 2011.
The University operates in the Higher Education Sector and aims to lead the world in research and education. We seek to do this in ways which benefit society on a national and a global scale. The University’s current strategic plan runs from 2018-2023.
The University is composed of academic departments and research centres, administrative departments, libraries and museums.
Oxford University Press is a department of the University, and not a separate legal entity. However, it has a different financial year end to the rest of the University and as such, has produced its own Modern Slavery Act statement. This statement is made in respect of the Press’s financial year ended 31 March 2020.
Employment and procurement are the main areas where there is a potential risk of slavery or human trafficking; the rest of this statement provides details of the University’s response to risk in these areas.
The University’s approach to recruitment, including specific expectations in respect of the recruitment of children is set out on the HR Support website.
At the point of recruitment, the University ensures that appropriate checks on prospective employees are completed in accordance with the law.
The University is committed to ensuring that people are paid appropriately for the work that they carry out. This commitment is set out in the information on pay structures.
The University provides its managers with guidance on the recruitment process.
The University is an accredited Living Wage employer. This means that the University has committed to pay both employees, and the staff of contractors and sub-contractors who work regularly (i.e. two hours or more over eight consecutive weeks within a year) on University premises in the UK at or above the Living Wage rate. The University is also an accredited Oxford Living Wage employer. All departments therefore pay the Oxford Living Wage or more to all employees and casual workers.
The University places the greatest importance on the integrity of its operations, and has in place a number of policies and procedures to address problems that may arise for its employees and students. Where there are genuine concerns about possible malpractices or improprieties that are not adequately covered by other University policies or procedures, staff are encouraged to make a public interest disclosure. This code of practice therefore provides an additional means for people to raise concerns about a supply chain or an individual who may be at risk.
The supply chain of the University includes a large number of diverse suppliers, including suppliers of goods and services that directly support research and teaching activity, for example large scale laboratory equipment and laboratory consumables, and suppliers of indirect goods and services.
In FY 19/20, the University’s spend fell into five main categories:
The University procures goods and services from suppliers across the world, and has supporting systems in place to identify and assess potential risk areas and to mitigate the risk of slavery and human trafficking occurring in our supply chains. These measures are described below.
The University requires suppliers to complete a due diligence questionnaire in respect of all contracts exceeding £100,000 (ex-VAT) in value, and recommends the questionnaire for use by departments when contracting between £25,000 and £100,000 (ex-VAT). This questionnaire includes a potential ground for rejection relating to convictions under the Modern Slavery Act 2015 and asks that suppliers confirm they comply with, and have written policies and staff training in place in respect of, s54 of the Modern Slavery Act 2015. In FY 19/20 this questionnaire was updated to request further information from suppliers on the steps taken to mitigate risk in their supply chains.
Modern slavery requirements have been included as a Pass/Fail question in the award of all recent frameworks established to support the University’s Estates Capital Projects. This includes Cost Consultants, Technical Designers and Constructors. The University’s Estates Services also make use of Constructionline, where level 2 and 3 registered suppliers must provide details on their policies and how these are communicated and enforced within their organisations.
For purchases under £25,000 (ex-VAT) a more limited due diligence checklist is recommended which asks suppliers to confirm there have been no convictions under the Modern Slavery Act 2015, or if there have been that appropriate steps have been taken to rectify the identified issues.
The University’s terms and conditions all include an obligation to comply with the Modern Slavery Act 2015.
All preferred suppliers have at least an annual review and are asked to provide written confirmation that no convictions have occurred in relation to the Modern Slavery Act 2015, or if a conviction has occurred that appropriate steps have been taken to rectify the identified issues. All preferred suppliers are requested to provide their Modern Slavery Act 2015 policy statement as part of the review documentation, and an additional question has been included in the review template to identify specific actions taken to combat modern slavery during the previous twelve month period. We expect this to prompt suppliers to improve their statements year on year.
New templates and guidance have been developed in FY 19/20 for use in preferred supplier reviews to further support the identification and management of supply chain risk. These prompt discussions with the supplier regarding the management of their onward supply chains. All members of the Purchasing Department have received training on these templates and guidance.
Following an initial review by the University, work on reviewing the LUPC and NETPositives tools is being taken forward by Southern Universities’ Purchasing Consortium (of which the University is a member). Once this review is completed we will assess the recommended tool for adoption.