Modern Slavery and Human Trafficking Statement
2020/21 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 utilizes APUC's managed contracts that cover some of the categories listed above. APUC's Modern Slavery and Human Trafficking Statement can be found here.
The Glasgow Clyde College Procurement Team currently utilises and is committed to the APUC Sustain Supply Chain Code of Conduct to underpin all tendering activity and supplier adoption.
The College is a 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 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’
The College is accredited by the Living Wage Foundation, which certifies that all staff are paid the real living wage. Non College contracted workers that regularly work onsite at the College are expected to be paid the UK living wage as defined by the Living Wage Foundation, and the College evaluates suppliers’ approach to Fair Work Practices including the Living Wage, in line with the Scottish Government’s statutory guidance.
Steps taken in 2020/21
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.
Procurement at the College continues to promote the use of the APUC 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.
At APUC there is a Category Responsible Procurement Champion who ensures commodity level risk assessment for modern slavery is carried out. APUC also has a Responsible Procurement Manager who assists at each tender process to embed sufficient measures to mitigate and address such risks. Where applicable, particularly within temporary staffing framework agreements and some Estates category framework agreements, checks are carried out that contractors hold a Gangmaster License.
APUC has been using Section 1 of its Supply Chain Management (SCM) tool to verify that its contractors have published Modern Slavery statements in line with the Modern Slavery Act 2015. APUC also conducts an assessment of its contractors’ compliance with the APUC Supply Chain. At tender stage contractors are asked to demonstrate the methods employed to ensure its compliance with the Modern Slavery Act 2015 and demonstrate how the transparency of its supply chain will be maintained for the duration of the framework agreement. Tender questioning specifically asks whether there are any controls to their recruiting system, whether recruitment agencies, labour brokers or any other intermediaries have any involvement in supplying labour on their behalf, and how risks associated with Modern Slavery are identified and mitigated by the contractor
A specialist multi-sector assessment service called Ecovadis has been introduced to APUC members including Glasgow Clyde College and this tool speeds up the practical delivery of supply chain performance assessments, Actions are created based on the outcome of the assessment (in relation to modern slavery these look at a variety of topics, including recruitment processes, employment terms, and workforce breakdown). The actions are shared with all contract managers that have a contractual relationship with that supplier. Actions may drive a further site visit to clarify certain points or investigate further.
Our Plans for the Future
Procurement staff will continue to participate in training and awareness sessions on sustainable procurement which includes Modern Slavery in the supply chain.
The Procurement Staff at the College shall continue to utilise the Sustainable Procurement Tools offered by APUC which includes a draft tender document, which includes full sustainable procurement references and a Modern Slavery Act compliance question, template strategy slides, the Supply Chain Code of Conduct, Prioritisation tool (based on the DEFRA Marrakech tool and the Scottish Government’s own updated tools), SCM (Supply Chain Management portal) and the Sustain tool, and a variety of eLearning (including on Human Trafficking and preparing a Modern Slavery Statement).
The College shall be inviting a cross section of strategic suppliers within this financial year to be assessed on the new Ecovadis system introduced by APUC.
This statement has been approved by the Glasgow Clyde College Board of Management who will review and update it annually.