At City, University of London we are committed to protecting and respecting human rights and have zero tolerance approach to slavery and human trafficking in all its forms.
At City, University of London we are committed to protecting and respecting human rights and have zero tolerance approach to slavery and human trafficking in all its forms. This statement is made pursuant to the requirements of Part 6 of the Modern Slavery Act 2015 and sets out the steps the university has taken and will continue to take in relation to slavery and human trafficking.
This statement sets out the steps that have continued to be taken during the financial year 2020/21 to try and prevent forced labour and slavery in our supply chain, our own operations and through involvement with our business partners. In line with guidance we aim to make progress over a period of time across a broader range of potential exposures, while in this year’s reporting set out the steps which have been our first priority under this new legislation.
Introduction to City
City, University of London, established in 1894, received its Royal Charter in 1966 and became a member of the University of London in September 2016. Over the last 126 years, City has become a leading education, research and enterprise institution with an annual income in excess of £240 million, working with over 22,000 students a year, and employs over 3,000 staff.
City’s Vision 2026
A leading global university committed to academic excellence, focussed on business and the professions and located in the heart of London.
- Transform the lives of our students
- Create new knowledge
- Support business and the professions
- Contribute to the global good of society
- Ambitious: a place where people seek new challenges and ‘go the extra mile’ to achieve the strategic priorities set out in our Vision & Strategy 2026 through implementation of their School or Professional Service Strategic Plan
- Collaborative: a place where successes are shared and problems solved by working together in partnership for the common good
- A Community: a place where people have pride in their institution, are respectful, know and look out for each other
- Diverse & inclusive: a place where diversity is a strength and inclusiveness is promoted proactively, with an initial focus on gender equality as City’s most pressing challenge
- Organisationally self-confident: a place that knows its strengths and is open about and strives to address its weaknesses.
City’s Strategic Priorities
- Maintain quality trajectory (‘better’): Build on the quality focus of the Strategic Plan 2012 to 2016 and maintain City’s upwards trajectory in research intensity, research quality, education quality and student experience.
- Achieve growth (‘bigger’): in a way which maintains quality. Growth is important to achieve the critical mass necessary for both research excellence and educational experience and effectiveness. Critical mass can result in improved quality without significant increases in costs.
- Leverage partnership: within City, within London (including through the University of London) and internationally with the aim of making us far more connected.
We recognise that modern slavery is a significant global rights issue and includes human trafficking, forced and bonded labour, child labour, domestic servitude, and sex trafficking. We are committed to protecting and respecting human rights and have zero tolerance approach to slavery and human trafficking in all its forms. We will act ethically and with integrity in all our relationships, and use all reasonable endeavours to take action directly and to influence others to ensure slavery and human trafficking is not taking place, wherever we can do so.
Our Human Resources policies set out our commitment to workplace rights at City, our Equality & Diversity policy promotes an enabling and inclusive environment in which all members of the City community are treated with dignity and respect.
We have well established procurement regulations which sets out our principles and practices for staff in acquiring goods, services and works, and outlines the steps we take to ensure the adoption of an ethical procurement approach with our supply chain and partners.
The Statement (on the steps in place and those that will continue to be enhanced)
Preventing modern slavery on our premises
We are vigorous in checking that our staff have the right to work in the UK, and where agency workers are used, City engage with agencies that have been through a procurement process prior to appointment to the supplier list to ensure adherence to the Act. The Finance and Purchasing training for new staff raises awareness for staff on the Act, City will continue to raise awareness among staff and students through a wide range of events, and where required with the relevant training.
City operates within a published ethics code that applies to all students, staff, (including affiliate staff such as visiting professors and visiting lecturer) and its independent members of Council and its Committees and all external parties acting on behalf of City. All parties have an individual responsibility (and in the case of external parties often a corporate responsibility) to uphold the principles, which have been approved by the Council and Senate. City will continue, to promote ethical behaviour and conduct by continuing to raise awareness with all stakeholders.
Ethics in Research
In addition to the scientific rigour of a project and the conduct of the researchers, an important aspect of research integrity concerns the ethical issues, in particular safeguarding any participants. Traditionally research ethics was a major concern in projects pertaining to biomedical research, but it is now considered in all disciplines involving human participants, as well as in relation to collection of personal data. It is recognised that there are differences between disciplines, but all research should be guided by the principle that human participants should be protected from harm. City's Research Ethics Committees are concerned with all aspects of the ethics of research investigations involving human participants and animal subjects carried out in the institution or under the auspices of the institution, by its Schools, staff or students. The Research Ethics Committees provide assistance to academic staff and associated general staff and students through the provision of compliance and policy advice and approval of research protocols containing ethical implications.
All proposed donations to City, of £10,000 and above are subject to a due diligence, with the detailed risk assessment approved at different value thresholds.
The President’s approval is required for values between £250,001 and £1,000,000 and Council approval where the value exceeds £1,000,000. City will continue to risk assess all donations within the thresholds, maintaining the rigour required.
Potential risk areas in our supply chain
We continue to identify high risk areas, for which the supplier’s Modern Slavery statement is reviewed and all new suppliers make a declaration of their awareness and adherence to the Modern Slavery Act and adherence to all relevant legislation in delivering the goods or services to City.
We will continue to get a better understanding of the supply chain, and will monitor those supply chains that have been identified as a potential risk and take appropriate action where necessary. Compliance to the Act is incorporated into the pre-qualification criteria for all tendered activity as well as full acceptance of City’s terms and conditions. City will continue to risk assess the supplier base, to target the awareness and adherence of the Act.
Use of Purchasing Consortiums
City works with a number of purchasing consortiums, such as the Southern Universities (SUPC) and London Universities Purchasing Consortiums (LUPC), all the consortiums used ensure the core principles of the Act are embedded within all supply chain activity.
City uses the standard Selection Questionnaire when advertising a tender to the market, which specifically asks questions of any prospective bidder which can be used to exclude them from the process. This follows from Regulations 57(1) and (2) of the Public Contracts Regulations 2015, regarding convictions, over the previous 5 years, for various offenses such as; ‘child labour and other forms of trafficking in human beings’. Furthermore, in relation to Regulation 57(3) there is also a Discretionary Ground for exclusion, regarding ‘breach of labour law obligations’.
City has also recently implemented a scored Social Value addendum to the Selection Questionnaire, which includes questions on ethical procurement and supply chain management, as well as Social & Community initiatives, Employment, and Environmental and Sustainability considerations (also in line with the expectations of The Public Services (Social Value) Act 2012). Those potential suppliers who are able to demonstrate they work hardest to promote ethical concerns will receive a higher score. Should it be evidenced that a prospective supplier has either been convicted and not made improvements as a consequence City reserves the right to exclude this supplier from the tender process.
Alternatively, if at a later date it can be evidenced that offenses were or have been committed that were not stated at the time of the tender, or subsequently, City reserves the right to terminate any contract. Furthermore, City will during the course of this year, enhance its proactive monitoring of its key contractual partners using an online engagement and monitoring tool (as used by the Higher Education Purchasing Consortia and a large number of Universities) which assesses the understanding and the actions of suppliers in terms of ethical credentials (including Modern Slavery), and it is expected this will be in place prior to the next update of this Statement.
Contractual terms and conditions
The core principles of the Act, are underpinned by City’s terms and conditions and in all contractual terms adopted. The standard terms and conditions are applied to all companies, and where ever possible City ensures that our terms and conditions are used, but in instances where a supplier’s terms are used or a specific contract is required, the university will conduct a full review to ensure that these principles are adhered to in full.
Community Volunteering and Unpaid Voluntary Work Placements
Our Community Volunteering Service exists to help students develop as civic-minded, well-rounded, and employable adults. As part of this aim, we employ best practices in sourcing volunteering placements, and we provide leadership on this subject within the Higher Education sector through the UK Student Volunteering network. The Community Volunteering Service works closely with our Employer Engagement job posting and matching team to assure consistency in our distinction between volunteering and unpaid voluntary work, as defined under Tier 4 Visa Guidance. The Employer Engagement Team provides guidance to ensure external employers are aware of their obligations under legislation concerning National Minimum Wage and Right to Work checks.
City remains committed to embedding sustainability across all of its activities, has an established Sustainable strategy and policy, with a supporting Fairtrade policy to embed core principles of fair trade wherever possible within City’s supply chain. City will continue to further promote Fairtrade principles wherever feasible in the acquisition and use of resources.
City has a whistleblowing policy and procedure which is designed to allow concerns of a public interest nature (as more particularly defined in paragraph 3.1 of the policy) arising in relation to City to be raised, investigated and where appropriate, acted upon. Concerns that are not of a public interest nature or which fall into an area covered by another procedure will not be considered under this whistleblowing procedure. Such concerns may therefore be considered under the other procedures of City. City will continue to raise awareness of the whistle blowing policy and procedure among all stakeholders.
If on City campuses, any alleged violation of the Act, in line with City’s policies and procedures, will be investigated and appropriate disciplinary action taken against any member of staff or student. If the violation is within our supply chain, City reserves the right to terminate the contract. In most cases City seeks to engage, improve, highlight and recognise our responsibility to support the identification, mitigation and eradication of modern slavery in our supply chain or with partners.
This statement has been reviewed by the Council of the university, and will continue to be reviewed annually. Any specific queries on the statement should be directed to the procurement team on firstname.lastname@example.org.