This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 ('the Act'). It aims to inform the University Court, our staff, students and the general public about the steps the University has taken during the last financial year, ending 31 July 2023 in relation to modern slavery and human trafficking.
University of Stirling Modern Slavery and Human Trafficking Statement
The University acknowledges that it has a duty to take a robust approach towards eradicating slavery and human trafficking in its business and throughout its supply chains and recognise that modern slavery is a significant global human rights issue.
We are a signatory to the SDG Accord, the University and College Sectors response to the United Nations Sustainable Development Goals (SDGs).
We welcome the opportunity to examine all our operations and practices where the University community can help to ensure that all people are free from lives of all forms of slavery.
Our annual statement reports the actions the University has taken in the last financial year and explains what we are going to do in the future.
The University is committed to preventing modern slavery and human trafficking in its activities and supply chains.
Our supply chains
The University procures a wide range of goods, services and works from a diverse supplier base. The risk of modern slavery in the University’s direct and local activities is low due to the mitigating measures that we have in place. However, we recognise the potential risks linked to certain global supply chains. Most of these goods and services are bought through collaborative contracts, and we work with the relevant contracting bodies to ensure due diligence measures are employed during their procurement processes, as well as in our own.
The University’s supply chain consists of circa 16,000 unique suppliers. Major non-pay spend categories are utilities, construction and maintenance, IT, professional services, lab equipment and consumables, and travel.
The University implements the UKUPC Sustain Code of Conduct for contracted suppliers as part of its standard requirements in its invitations to tender. Section 1 of the Code prohibits forced, involuntary or underage labour.
The University’s Terms and Conditions of Purchase set out our expectations for our suppliers in relation to human rights and the elimination of modern slavery and human trafficking in their supply chains.
The University evaluates suppliers’ approach to Fair Work First, including the Living Wage, in line with the Scottish Government’s statutory guidance.
Measures included within the Public Contracts (Scotland) Regulation 2015 are embedded in all our procurement activities. Every regulated procurement process undertaken by the University requires tenderers to disclose whether they, or any member of their organisation with decision‐making powers, has been convicted in the last five years of any offence under Part 1 of the Human Trafficking and Exploitation (Scotland) Act 2015 or under any provision referred to in the Schedule of the Act.
The University is a member of APUC and supplements its own efforts with support from that sectoral Centre of Expertise. (See the APUC Modern Slavery and Human Trafficking statement). APUC’s Responsible Procurement Policy informs a clear commitment to responsible procurement.
The University continues to support various ‘live’ cross-sectoral initiatives to address modern slavery risk in supply chains.
The University is an associate member of Electronics Watch (EW), an independent monitoring organisation working to achieve respect for labour rights in the global electronics industry through socially responsible public purchasing in Europe.
Our risk mitigating policies
The procurement policies provide a broad regulatory regime under which all procurement activity must operate. The procurement procedures translate these policies into processes and procedural standards. Both the policies and the procedures take full cognisance of the legislative framework for public procurement in Scotland.
The risk of modern slavery occurring in the University’s workforce is mitigated by ensuring that staff are recruited following robust recruitment policies (including right to work pre-employment screenings undertaken prior to all appointment being made). We are rigorous in checking that all new recruits have the right to work in the UK.
Raising concerns (whistleblowing) policy
The University is committed to the highest standards of openness, probity, and accountability. This policy is designed to encourage staff and other members of the University to speak up if they have any concerns at work as this will help the University to address any issues, improve the way we operate and the services we provide to students and other stakeholders.
The University’s Safeguarding Framework and supporting student referral pathways set out the University’s commitment to fostering a safe and protected environment for the University community. The procedures set out the steps that would be followed if a member of the University community has a concern that a student may be at risk or harm, or be a victim of systemic exploitation or abuse, such as human trafficking, modern slavery, forced marriage or honour-based violence.
Summary for financial year ending 31 July 2023
The University continued to address modern slavery directly by setting minimum standards, ‘fit for purpose’ specifications and appropriate contract management.
Procurement managers continued to analyse ‘at risk’ supply chains as part of their ongoing category management activity. Additional mitigating measures were adopted as appropriate.
APUC’s Supply Chain Management (SCM) tool was adopted for use by Procurement Services. Through SCM, suppliers are asked to provide details of measures they take in relation to modern slavery in their supply chain, including any third-party accreditations and assessments to evidence this.
Awareness and training
Procurement Services continued to raise awareness of modern slavery and human trafficking issues across the University community – how to identify risks and how to put in place mitigation or management measures – through its ongoing stakeholder engagement.
All Procurement Services staff undertook the revised Ethical Procurement and Supply eLearning and Test provided by the Chartered Institute of Procurement and Supply (CIPS).
In 2022/23 there were no requirements to terminate business with any suppliers on the grounds of contravention of the Modern Slavery Act.
Action plan for financial year ending 31 July 2024
We will implement and develop the following action plan to identify and mitigate any risks that modern slavery and human trafficking are present in our business and in our supply chains.
Revised procurement strategy
In 2024 the University Procurement Strategy will be revised. This will reaffirm our commitment to mitigating the risk of modern slavery occurring in our supply chains.
A modern slavery policy
A new policy will be drafted which sets out the University’s commitments and responsibilities in relation to modern slavery.
Procurement Services will consider the value of implementing EcoVadis to access better CSR data on our supply chain. EcoVadis assess suppliers across twenty-one sustainability criteria in four themes, environment, labour & human rights, ethics, and sustainable procurement, based on leading international standards.
Review and approval
This statement will be reviewed annually.
Professor Sir Gerry McCormac, Principal and Vice‐Chancellor