Modern Slavery Statement

University Of Plymouth (and subsidiary companies) Modern Slavery and Human Trafficking Annual Statement

This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and constitutes the University of Plymouth’s slavery and human trafficking statement for the financial year ending 31st July 2024.

Introduction

Modern slavery takes many forms including slavery, servitude, forced and compulsory labour, child exploitation and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
The University of Plymouth (the “University”) remains committed to continually improving its practices to combat slavery and human trafficking, protecting and respecting human rights.

Our structure

The University is renowned for high quality, internationally leading education, research and innovation. The University makes a positive difference to people’s lives and with a truly global outlook, the University is an inclusive and inspiring community.
The University is an independent Higher Education Corporation and an exempt charity under the terms of the Charities Act 2011, with the Office for Students (OfS) acting as the principal regulator.
The University's structure extends to include six subsidiary companies (the ‘Group’). The Group includes; Peninsula Dental Social Enterprise CIC (PDSE), PDSE Limited (PDSEL), PMS (Facilities) Plymouth Limited, (PMSF), University Commercial Services Plymouth Limited (UCSP), University of Plymouth Enterprise Limited (UPEL) and University of Plymouth Services Limited (UPSL).

Our policy on slavery and human trafficking

In pursuit of it’s Mission the University procures a truly diverse range of goods, services and works.
The University recognises that it is possible for instances of modern slavery to occur in any supply chain and is committed to acting ethically and with integrity; and will not tolerate modern slavery or human trafficking in its supply chains.
The University is able to evidence this commitment of acting ethically and with integrity through a number of its policies, including (but not limited to):
Through this combination of individual policies the University commits to continually improving practices that combat slavery and human trafficking.
Direct tendering activity for the purchase of goods, works and services by the University will, by default use of the University’s standard Terms & Conditions which contractually require suppliers to comply with all applicable laws in relation to antislavery and human trafficking including the Modern Slavery Act 2015; to establish due diligence procedures for their own suppliers, subcontractors and other participants in their supply chains; and to ensure that there is no slavery or human trafficking in their supply chains.
The University’s tendering processes ensure that there is consideration for modern slavery risks when procuring goods, services and works above the tendering thresholds in our tendering policy. In addition, the supplier on-boarding processes support the University’s anti-slavery and anti-human trafficking values, to ensure the potential for modern slavery and human trafficking are duly considered at the early stages of the contracting cycle.

Training

The University promotes resources and increases awareness to its staff through internal webpages. These include access to external e-learning modules on the following topics:
  • Guide to Modern Slavery; and
  • Protecting Human Rights in the Supply Chain.
The University also promotes externally available resources to colleagues such as thee UK Modern Slavery & Exploitation Helpline (Unseen).

Supply chains

The University’s supply chains are truly diverse, with over 2,000 suppliers (domestic and international) supporting the delivery of high-quality teaching and research.
All suppliers are assigned a commodity code helping to identify those who trade in commodities where potential for Modern Slavery and Human Trafficking is considered a higher risk. This insight is used to inform the University’s sourcing activity.
The high-risk commodities areas have been identified by the University as:
  • Audio-Visual, IT & Multimedia Supplies;
  • Catering Supplies & Services;
  • Furniture, Furnishings & textiles;
  • Janitorial & Domestic Supplies & Services;
  • Professional & Bought-in Services including consultancy;
  • Travel & Transport (incl. Vehicle hire & Subsistence);
  • Estates & Buildings;
To inform sourcing decisions across these commodity areas, the University draws reference from market intelligence and insights. This information comes from a range of sources and partnerships for example UKUPC Market Insight Report and through membership with Electronics Watch.

What have we done in 2023/24

This statement relates to the University’s financial year from 1 August 2023 to 31 July 2024.
In October 2023, the University again raised awareness of the issues surrounding modern slavery and human trafficking, amongst colleagues throughout Anti-Slavery Week 2023, culminating on Anti-Slavery day on the 18th October 2023. Internal communication channels were used including the weekly staff bulletin, to increase awareness and visibility along with a refresh of a dedicated internal website.
The University has progressed the 2022/23 review of the University’s activities against the British Standard BS 25700 ‘Organisational responses to modern slavery’. A Modern Slavery Statement Working Group was established with colleagues from Legal, Procurement, Finance, TIS, HR, Estates, and Risk with agreed terms of reference for the Working Group.
The inaugural meeting of the Working Group took place in November 2023 and the Working Group has continued to then meet bi –annually. A key activity of the Working Group has been to progress a 24-month rolling action plan of activities, modelled against the British Standard. This activity has resulted in the completion of several initiatives, alongside identifying further activity for completion in 2024/25.
Activity in year includes:
  • Training - Development of a Modern Slavery eLearning module to support improved awareness of modern slavery and human trafficking issues amongst staff and improve reporting of staff up take.
  • Awareness - Additional training and engagement by HR Teams and those involved in recruitment to improve awareness of modern slavery risks. EDI team within HR have completed modern slavery eLearning.
  • Recording & Reporting - Enhancement to Speak Up, the University’s hate, harm and abuse reporting platform, have been scoped, to support the local reporting of modern slavery concerns by staff, students and contractors whilst continuing to promote the Unseen helpline.
  • Recruitment: Processes around right to work checks have been reviewed in year to ensure the good practice detailed in BS 25700 is being applied.
In July 2024, the University’s Procurement team was reaccredited with the Chartered Institute of Procurement and Supply (CIPS) Corporate Ethics Mark. This makes clear, there is a commitment to responsible sourcing and evidences honing of procurement skills and knowledge in support of ethical supply chains practices.
Also in July 2024, the University’s subsidiary, University Commercial Services Plymouth Limited (UCSP) which runs the onsite catering and nursery facilities, achieved a two-star Fairtrade status following their activity as part of the 2022-2024 cohort for the jointly delivered Fairtrade Foundation and Students Organising for Sustainability UK (SOS-UK) initiative. The Fairtrade University Award gives recognition to institutions that have embedded ethical and sustainable practices through their curriculum, procurement, research and campaigns.
The University continues to recognise those supply chains that represent a risk of modern slavery, human trafficking, forced and bonded labour, and labour rights violations. In this reporting period, the University has not found evidence of labour rights exploitation in any supply chain to the University. However working with Electronics Watch, a report was issued relating to an investigation into the production of desktop IT equipment. This has been referred by Electronics Watch to the RBA (Responsible Business Alliance) who are carrying out a further audit. Once complete the University will review findings and work with Electronics Watch should actioned be required to ensure the University stance on labour rights violations is preserved.
The University’s position remains that if the University does identify instances of, or is alerted to the risk of modern slavery in its supply chain, relevant action will be taken, which may include undertaking an investigation, liaising with the supplier and/or informing the police etc. In such instances and pending an internal review, if the University is unable to secure a positive response to the concerns this may result in the University exercising its right to terminate the relevant contract.

What we are going to do in the future

The challenge of modern slavery and human trafficking is one that is best addressed through the ongoing and proactive engagement with suppliers, members of the UK Universities Purchasing Consortia (UKUPC) and wider professional networks such as HEPA (Higher Education Procurement Association), through which sharing of experience will establish and maintain best practice.
During the Financial year ending 31st July 2025, the University intends to:
  • Progress the rolling action plan aligned to the British Standard (BS) 25700:2022 ‘Organizational responses to modern slavery’, overseen by the Modern Slavery Statement Working Group.
  • Launch to staff, a voluntary internal Modern Slavery eLearning module to improve accessibility to such resources for all colleagues and allow the reporting of uptake to inform future recommendations.
  • Roll out enhancements to the University’s Speak Up platform to accommodate the reporting modern slavery concerns. To be used when externally available mechanisms (such as Unseen) could create a barrier to reporting concerns. We will cascade this across teams, working with Student Services and University of Plymouth International College and the University of Plymouth’s Student Union (UPSU).
  • Maintain the University’s Fairtrade commitment. As part of the 2024-2026 cohort, we hope to build on our two-star fairtrade achievement; by pursuing the highest three-star award. We will be working with the Fairtrade Foundation and Students Organising for Sustainability UK (SOS-UK), under the Fairtrade University and College Award.
  • Maintain the journey of improving internal awareness of modern slavery risks by supporting and promoting the annual event of Anti-Slavery Week.
  • Update the University’s standard terms and conditions to enhance provisions relating to modern slavery and legal compliance.

Annual statements