Modern Slavery Act statement

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 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 130 years, City has become a leading education, research and enterprise institution with an annual income in excess of £246 million, working with over 22,000 students a year, and employs over 3,000 staff.

City’s implementation of its new forward-looking Strategy is now beginning to see beneficial results. Our core values are:

We are the university of business, practice and the professions

1. We build successful and fulfilling careers and develop leaders for the world of work

• Understanding, celebrating and empowering our students – the students who choose us, and whom we choose – and delivering enriching and personalised educational experiences.
• Creating a diverse and vibrant community of learning that reaches far beyond the University and is sustained through powerful networks.
• Providing relevant skills, attributes and approaches that enable our graduates to succeed in their future careers and life pathways.

2. We undertake research at the frontier of practice

• Fostering important, impactful and engaged research.
• Educating professionals for whom evidence-based thinking is integral to their practice.
• Challenging practice and redefining the professions.

3. We are a flexible, high-performing learning organisation

• Building a great place to work that is inclusive, supports wellbeing and is a fun place to be.
• Creating an accountable, socially responsible, efficient and responsive organisation that can deliver this strategy.
• Operating a robust and sustainable financial margin that ensures we have the space to achieve our mission.

4. We are open and outward-facing

• Comfortable with partnership and happy with co-creation – the opposite of an ivory tower.
• Ambitious, innovative and risk-taking – not afraid to be different.
• Embedded in London, a world capital, and proud of our deep connections with the City of London.

Our community, our values

We care

• We care for each other and for the world around us. We are inclusive, collegial, and value diversity.

We learn

• We (re)think. We are curious, rational thinkers who make decisions based on the best available information. We are open-minded and inquisitive. That means that we are never too wedded to our assumptions. If we uncover new insights indicating that we should change our mind, we do.

We act

• We shape the world through our actions. We always act with integrity. When we can change something for the better, offer help, or make a difference, we choose to do so.

Reflecting these values involves ensuring that our wider community, including our suppliers and supply chains – and those employed by them – care, learn and act on important issues such as Modern Slavery.

Our Commitment

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 engages with agencies that have been through a procurement process prior to appointment to the supplier list to ensure adherence to the Act.

Ethics Code

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.

Donations

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. SUPC has recently worked closely with Electronics Watch (EW) to offer its members affiliation with EW which will be a useful source of intelligence on supply chains in technology markets. Information on human and labour rights issues in technology supply chains is now freely available to City.

Proactive Management of City Suppliers and their Supply Chains

City has implemented NETpositive Futures (NpF), a tool used by a large number of HEIs to engage with its suppliers and monitor performance against a number of Sustainability and Social Value Criteria, which includes their response to the Modern Slavery Act.

Onboarding New Suppliers

Where a requirement is lower value (i.e. below £50,000), and a less formal competitive quotation process has been undertaken, successful suppliers are instructed to complete a Supplier Information Sheet. This already includes self-declarations regarding compliance with UK Law, including the Modern Slavery Act and UK GDPR. City has update this form to include an invitation to register on NETpositive Futures, if they have not already done so, as a way to understand and engage with our supply-base (and in particular MSMEs and local businesses) to promote and support alignment with City’s values where appropriate. At this lower value of business, it is not City’s intention to mandate the use of NpF. Procurement also reserves the right to require further, more detailed checks in line with its tendering obligations, where an initial low value purchase escalates over time (see Tendering Processes, below).

For all other suppliers awarded business as a result of a tender, City is now making it mandatory to register on NpF, complete the questionnaire and report on Action Plans put in place as a result of this process (or otherwise). Specific content from NpF is shown below in Annex 1. City will monitor each supplier’s progress against the actions set out, not only as part of contract management but also as part of supplier improvement processes, with the objective of securing completed action plans with supporting evidence that the measures agreed have been put in place. City is currently in the process of cleansing City-specific content in NpF, in which 83 current City suppliers have already registered. City is also committed to emailing all contracted suppliers over the next 12 months who are not already registered instructing them to do so. As the number of suppliers registered on NpF increases, City will be able to provide detailed statistics regarding progress.

Tendering Processes

City uses the standard Selection Questionnaire (the ‘SQ’) 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”. The Cabinet Office guidance published to accompany the SQ makes clear the consequences of misrepresentation, in that any decision may be set aside, or if a contract has already been entered into the supplier may be sued, have the contract rescinded, and/or be prosecuted for fraud by misrepresentation. 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 toterminate any contract. It is made clear to all bidders that if they are successful they will be required to engage with NpF as part of their onboarding process, and that their progress on the actions identified will be monitored as part of the contract management process.

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. The City Terms and Conditions of Contract have been amended, including making it clear that non-compliance with the Act, if not remedied, or if incapable of remedy, will be treated as a Material Breach, reserving therefore City’s right to terminate the contract.

Forthcoming changes to UK Law

Following on from the release of a green paper ‘Transforming Public Procurement’, and the consultation of numerous buying and supply organisations, it is expected that a white paper was presented to Parliament in Spring 2022 aiming to replace the Public Contracts Regulations 2015. This will include the proposal to change the way contracts are awarded from ’Most Economically Advantageous Tender’ (MEAT), to ‘Most Advantageous Tender’ (MAT). This, when allied with a proposal to broaden award criteria to include areas not relating to the specified good, work or service, will give City greater scope to evaluate tenders on a variety of other considerations, including Ethical Procurement, Social Value and Sustainability. In certain markets where Modern Slavery has traditionally been identified as an issue – raw materials, technology, apparel, as well as hotel services such as cleaning or in construction, this will mean that City can more explicitly award a contract based in part on these considerations. The Procurement Act 2023 (and Procurement Regulations 2024) have been passed by Parliament, and it is expected that these will become law to coincide with an updated National Procurement Policy Statement, at this point anticipated to be 24^th February 2025.

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.

Sustainability

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.

Whistleblowing

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 procurement@city.ac.uk.