Modern Slavery and Human Trafficking Statement
2019/20 Financial Year
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour 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. Glasgow Clyde College rejects modern slavery in all its forms.
Glasgow Clyde College recognises that it has a responsibility to take a robust approach to slavery and human trafficking. This statement sets out the College’s actions and commitment to understanding potential Modern Slavery risks related to its activities and to minimise the risk of slavery and human trafficking in its supply chains for goods and services.
This statement is made in connection with section 54(1) of the Modern Slavery Act 2015 and sets out the steps the College has taken and will take in relation to slavery and human trafficking.
The College is committed to ensuring that modern slavery and human trafficking is not taking place in any part of its operation within the College and its supply chain. We are committed to protecting and respecting human rights across the College’s activities, and will take reasonable and appropriate steps to influence others to ensure slavery and human trafficking is not taking place, where it is possible to do so.
Supply Chain Expenditure
Glasgow Clyde College’s supply chains mainly fall under six categories, which are:
- Estates Goods and Services
- ICT Equipment and Services
- Professional Services
- Library Resources
- Laboratory Consumables and Equipment
- Human Resources
The principal categories, which carry risks, are office supplies, laboratory consumables, ICT equipment and some estates services, such as cleaning, waste and security services.
Our Procedures on Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our procedures reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Glasgow Clyde College have embedded sustainable procurement practice throughout its Procurement Procedures, to which we are committed.
APUC (Advanced Procurement for Universities and Colleges) Limited is the procurement centre of expertise for all of Scotland's universities and colleges. APUC pursue opportunities for collaborative procurement. Collaborative tenders are led or jointly managed by APUC on behalf of institutions by working with other purchasing consortia across the UK where it adds value by doing so. Glasgow Clyde College is a member of APUC and currently utilises APUCs managed contracts that cover some of the categories listed above. APUCs Modern Slavery and Human Trafficking Statement can be found here.
The Glasgow Clyde College Procurement Team currently utilises and is committed to the APUC Supply Chain Code of Conduct to underpin all tendering activity and supplier adoption.
To assess our suppliers’ compliance with the Supply Chain Code of Conduct, APUC had developed a web-based assessment tool (SUSTAIN) linked to the contracts database containing contracts/agreements used by the whole sector. The website assessed suppliers at three achievement/compliance levels in social, ethical, economic and environmental areas. The tool enabled contract managers to view the status of their suppliers, and for sub tier suppliers to be linked and then assessed.
The Sustain tool question set has now been merged with the Equiano tool used by partner consortium LUPC (London University Purchasing Consortia) to develop SCM – Sustain. This has further questions around Contractors’ modern slavery statements as well as the original (updated) Sustain question set. This has been embedded into a new Supply Chain Management (SCM) tool launched by APUC for its members in late 2019 and enables modern slavery risk assessments to be fully integrated with supplier management processes.
APUC is a Founder Member 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. They have recently published their Monitoring Methodology Guidance and Code setting out standards for the production of Goods. APUC’s Head of Development & Sustainability also sits on the board of Electronics Watch.
APUC is also actively involved in several cross-sector initiatives relating to addressing modern slavery risks in supply chains. These include the HEPA (Higher Education Procurement Academy) responsible procurement group, the ETI (Ethical Trading Initiative) public sector working group on modern slavery, the Make ICT Fair project and the Procura+ group ‘Socially Responsible Public Procurement of ICT’
Steps taken in 2019/20
The College has updated the clause within its General Terms and Conditions in relation to Modern Slavery. This outlines the obligations of the supplier in contracting with the College. It extends to due diligence procedures being in place for sub-contractors to that supplier. It references the requirement for suppliers to comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes (including the Modern Slavery Act 2015).
Buyers were made aware of free access to the HEPA (Higher Education Procurement Association) eLearning module on “A Guide to Modern Slavery”. In addition to the HEPA Modern Slavery training, members of the procurement team have taken part in training and awareness raising sessions organised by APUC.
Our Plans for the Future
Glasgow Clyde College expresses its commitment to better understanding its supply chains and working towards greater transparency and responsibility towards people working in them.
Working with our suppliers, we can map out those supply chains, which represent a medium to high risk of modern slavery, human trafficking, forced and bonded labour and labour rights violations.
As part of our initiative to identify and mitigate risk, Glasgow Clyde College commits to:
- Responsible procurement and embedding this in all procurement activities
- Identify and assess potential risk areas in our supply chains
- Mitigate the risk of slavery and human trafficking occurring in our supply chains
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers and report unethical conduct.
- Where possible, build long-standing relationships with our supply chains to ensure these entities have and follow suitable anti-slavery and human trafficking policies and processes.
The Glasgow Regional Procurement Team have a Responsible Procurement Champion for the region. Their responsibility is to drive implementation of the Sustainable Procurement Policy. The Sustainable Procurement Policy requires that consideration is given to the environmental, social, legislative and economic consequences for design, materials used, manufacturing methods, logistics and disposal of any procurement decisions.
APUC has undertaken a refresh of the prioritisation exercise on all collaborative framework agreements which they lead on, to identify areas where Modern Slavery may be occurring and to take appropriate action to ensure that these framework agreements exclude the use of modern slavery practices. Procurement at the College continues to promote the use of these framework agreements within the institution and as such we can be confident that our supply chain has been analysed when contracting under these agreements. We will look to increase reliance on these collaborative frameworks which will reinforce the compliance with our policies.
Procurement staff will continue to participate in training and awareness sessions on sustainable procurement which includes Modern Slavery in the supply chain.
Where possible, within our own tenders/contracts, we will continue to address areas of concern for modern slavery directly in the tendering process through minimum standards, specification and contract management.
This statement has been approved by the Glasgow Clyde College Board of Management who will review and update it annually.