Modern Slavery Statement
Buckinghamshire New University and its wholly owned subsidiaries recognises that modern slavery is a crime resulting in an abhorrent abuse of human rights and includes slavery, servitude, forced or compulsory labour, and human trafficking. We are committed to protecting and respecting human rights and to ensure that slavery and human trafficking is not taking place within our organisation, its subsidiary companies, or in any of our supply chains.
This statement is made pursuant to Section 54, Part 1 of the Modern Slavery Act 2015 to prepare a slavery and human trafficking statement for each financial year of the organisation and to set out the steps taken during the particular financial year to ensure that slavery and human trafficking is not taking place in any part of its own business or in any of its supply chains.
The University’s structure, business, and its supply chains
Buckinghamshire New University is a new generation University established in accordance with the Education Reform Act 1988 as amended by the Further and Higher Education Act 1992. We are an exempt charity by virtue of the Charities Act 2011, and subject to regulation by the Office for Students (OfS). Our core business is the provision of education and sharing of knowledge; and our vision is to be a leading University for professional and creative education and applied research. In terms of our widening participation and outreach activities we also work with a range of national and educational partners under formalised partnership arrangements.
The University is structured into nine Academic Schools (Art, Design and Performance; Aviation and Security; Business and Law; Creative and Digital Industries; Health and Social Care Professions; Human and Social Sciences; Nursing and Midwifery; Missenden Abbey Hotel and Hospitality School and School of Engineering and Built Environment). Schools are supported by several central service directorates to support our academic programmes and provide professional services. The University has a wholly owned subsidiary company, Missenden Abbey, which provides a hotel, conferences, and management training events.
The University formally recognises two trade union bodies to represent its employees. The University and College Union (UCU) covers members of academic staff, while UNISON covers professional service employees. The University works with representatives of both trades unions to negotiate and discuss terms and conditions of employment, relevant employment policies and procedures, and working conditions.
The University’s supply chains broadly fall within the following 'top-level' categories:
- Estates and facilities management (work, services and goods)
- ICT equipment and services
- Professional services
- Teaching materials
The principal areas that carry material risks in relation to modern slavery and human trafficking are office supplies, laboratory consumables, ICT and AV equipment and some estates and facilities management services.
Policies and procedures
The University is committed to ensure that there is no modern slavery or human trafficking in its supply chains or in any part of its business. It already has in place a framework comprising core values, policies and processes that demonstrate its commitment to acting ethically and with integrity in its business relationships. The University will continue to keep this framework under review, together with its procurement and supplier management procedures, to assess their effectiveness in identifying and tackling human trafficking and modern slavery issues and refine where relevant.
All our policies, procedures and regulations can be found on our website and internal intranet as appropriate. Any employee found to have been acting in breach of our stated policies can be subject to our Disciplinary Policy and Procedures.
People working on our campuses
Our Human Resources policies support employees, our core values as a university, and the Code of Conduct sets out our expectations of employees in relation to standards of behaviour, professionalism and commitment. Our Respect, Fairness, and Inclusion Policy ensures that everyone within the University has the right to be treated with respect, while our Raising Issues of Concern (Whistleblowing) policy allows employees to disclose information without fear of penalty which they believe shows malpractice or illegal practices in the workplace. If any incidences of modern slavery or human trafficking were to be suspected on site, it is essential these are reported. Employees can report it to the University in confidence and anonymously;
- Report to University management
- Tell their Heads of Schools/Directorate leads, line manager or supervisors
- Report confidentially by email to email@example.com
- Report to the Procurement team
Any staff that are sub-contracted to work on our campus can report this to their line manager or supervisor in line with their organisation’s policies and procedures.
We have robust recruitment and induction processes for all new and current employees, and this covers key people policies and procedures of the University.
If actual instances of modern slavery, human trafficking or any other human rights violation are identified in the supply chain or on-site relating to staff, law enforcement can be involved to redress the harm to the victims and provide better options for the future.
If it is suspected that someone is being exploited, the following contact numbers are
- The University main switchboard 01494-522141
- 999 if there is immediate risk of harm
- 101 Police
- 08000 121 700 Modern Slavery Helpline
Our Finance policies and regulations provide control over use of the University’s resources and provide Council, our governing body, with assurance that resources are being properly applied and appropriate controls are in place. Our Procurement Procedure sets out the processes whereby we acquire goods, services and works.
Due diligence and risk assessment
The University’s Procurement teamwork closely with other universities and the University is a member of the Southern Universities Purchasing Consortium (SUPC). SUPC publishes its own Modern Slavery Statement and has registered with the Transparency in Supply Chains Platform (TISC ) report website as a demonstration of its compliance to its commitment to eradicating Modern Slavery throughout the SUPC supply chains supporting higher education. SUPC is also in turn a member of Procurement England Limited (PEL), the share vehicle by which English higher education purchasing consortia manage joint developmental and improvement projects for collaborative procurement in our sector. Together, the purchasing consortia have published a shared Sustainability Policy to which all PEL member consortia are committed. This policy contains steps that form part of the supplier selection for the major contract procurement processes that are conducted for the consortium members.
In conjunction with the SUPC, The University’s Procurement function also work with and procure from other Government backed purchasing Consortia such as the Crown Commercial Services (CCS) in cases where SUPC are unable to offer certain services and supplies the University needs. All the Consortia the University uses are broadly comparable with the SUPC when it comes to the rigor in their approach to eradicating Modern Slavery in their Supply Chains.
Our Facilities Management Services contracts ensures that employees under the contract are all subject to the National Living Wage and this includes all contracts at the University owned and operated residential Hotel Missenden Abbey. This covers cleaning, security, maintenance, pest control and business support services. As we proceed to re-tender our maintenance contracts, an element of Modern Slavery Act 2015 requirements as a Pass/Fail has been introduced to this process as a criterion for evaluation.
ICT Equipment and Services
We continue to direct more spend for ICT equipment and services via the SUPC and other comparable government and HE supported purchasing frameworks such as the HE Joint Information Systems Committee (JISC) purchasing consortia frameworks.
SUPC leads in the procurement of servers and storage equipment as well as IT-related parts and accessories for UK higher education institutions and other members. They also play an active part in the management of supply agreements led by sister consortia for Apple products, desktop computers and notebooks and other ICT equipment.
SUPC supports the principles of Electronics Watch, an independent monitoring organisation working to achieve respect for labour rights in the global electronics industry through socially responsible public purchasing in Europe. The Electronics Watch contract monitoring clauses are included in relevant agreements that are awarded. During early 2017 Electronics Watch reviews and audits have been conducted at factories operated by sub-contractors to suppliers including Apple, Dell and HP in China, India and the Czech Republic.
Professional Services relating to Temporary Recruitment via agencies
The University mainly uses Staff and Recruitment Agencies that are on either the SUPC or CCS Purchasing Consortia Frameworks and, these Agencies comply with the Consortia’s Policies, Procedures and Practices in relation to eradicating Modern Slavery. If there is a requirement to go outside the above frameworks, we ensure that the agency/ies used are also compliant in relation to eradicating Modern Slavery.
The Procurement Team will continue to deliver guidance relating to Modern Slavery for all professionals across the organisation who engage with the University’s suppliers and related contracts.
A more informal training will be available for remaining employees via an alternative e-portal. The intention is to raise awareness and educate our employees about Modern Slavery and our Corporate Social Responsibility regarding this issue. Also, it is a mandatory requirement for staff to complete safeguarding and Equality, Diversity, and Inclusion training. This is undertaken immediately on starting at BNU and then refreshed every two years.
The University’s commitment to inclusivity
The University’s diverse community helps make studying and working at this University inspiring, fun, and creative. This University has a proud history of valuing the importance of inclusion and it will continue to play its part to challenge inequality and build a fairer society. Equality, diversity, and inclusion is key to the university’s strategy. This underpins how the University respects and value others and champions an inclusive community that transforms lives.
This commitment to inclusivity the University has will also support its commitment to protecting and respecting human rights and to ensure that slavery and human trafficking is not taking place within our organisation, its subsidiary companies, or in any of our supply chains.
The University has formalised partnership agreements with all its Educational Partners. Through the University’s process of securing partnership agreements, due diligence is carried out to ensure the University’s partners comply with the prevailing Modern Slavery Act in terms of their policies, procedures and practices that fall within the scope of the University’s partnership agreement with them and their wider organisational activities. To ensure continued compliance, monitoring is carried out by the University with its Partners particularly at formal annual reviews.
Further actions and goals
For 2022-23, the University’s total third party and supplier spend was £45.56M (Inc Vat) and out of this £43.32M (95%) was spent through compliant Government backed framework purchasing Consortia suppliers, or from duly tendered or partnering third party arrangements where the resulting Contracts ensured that Modern Slavery safeguards are in place. The remaining amount of spend ostensibly involve a multiplicity of very low value non-recurring spot purchases and the University does monitor this low value spend activity.
A recent reorganisation of the University’s Finance Team involving the Accounts Payable and the Procurement Teams, does mean that the Procurement Team will continue to look at smaller amounts of expenditure duly aggregated into a category of spend and assess if there is enough justification to explore any potential Modern Slavery implications.
The University will now support and adopt the SUPC recently developed NET positive Supplier Engagement Tool. This tool (alongside other tools and guidance available to the University) allows suppliers to the university to develop a plan which ensures they are engaging with their own suppliers regarding the development of appropriate Modern Slavery action plans and monitoring.
The University will also continue to make use of the Central Government’s supplier Modern Slavery Assessment Tool as a guide (MSAT) provided by the Crown Commercial Services (CCS) organisation and seek their related guidance as and when required. This recent development by CCS will now allow the University to receive Modern Slavery impact assessments on all the University’s suppliers (including those that service and supply Missenden Abbey) that might be affected by Modern Slavery within their own supply chains and take the appropriate action. This MSAT tool is used to assess and ask suppliers who trade in high-risk areas to commit to the internationally recognised Base Code of Ethical Trading that is founded on the International Labour Organisation and is an internationally recognised code of labour practice, requiring that suppliers check within their supply chains that:
- Employment is freely chosen
- Freedom of association and the right to collective bargaining are respected
- Working conditions are safe and hygienic
- Child labour is not used
- Living wages are paid
- Working hours are not excessive
- No discrimination is practised
- Regular employment is provided
- No harsh or inhumane treatment is allowed
The University follows a devolved procurement structure. The aim is to reduce the number of engagements and spend whereby little or no due diligence has been undertaken with suppliers prior to contract acceptance and implementation. This objective is achieved by ensuring that the procurement team continue to engage and support people who are involved with the procurement of goods and services for their departments and schools. Also, the procurement team will carry on monitoring and authorising purchase orders and the set-up of suppliers within the Universities Business Connect procure to pay system involving individual non-pay spend above £5K.
Staff are empowered to undertake assessments of Modern Slavery for prospective suppliers as part of their due diligence and the MSAT will help them do this. Their empowerment will be supported by the Procurement team and in particular the use of the Universities or SUPC tender and contract award documents that legally bind suppliers (where applicable) into delivering as defined by section 54 (“Transparency in supply chains”) of the 2015 Modern Slavery Act
Modern Slavery has been added to the University’s risk register to ensure that processes are monitored at regular intervals.
When the University partners or works alongside other organisations, and in particular education and training partners, it continuously considers the longer-term view of the processes for Modern Slavery. BNU will continue to ensure that robust, legally binding contractual arrangements with its partners are in place to ensure Anti-Slavery and Human Trafficking activities are not going on in any parts of the University’s business or its partnering supply chain.
The safeguards in the University partnership contracts are also underpinned by the University’s robust due diligence procedures and approval processes before the intended partnering institution is proposed and adopted as a partner of the University.
Approved by Maggie Galliers CBE, Pro-Chancellor and Chair of Council, at the full meeting of Council held on 28 November 2023.