Introduction
Modern slavery is a crime and a violation of fundamental human rights. It can take 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 to exploit them for personal or commercial gain.
The University is committed to preventing modern slavery and human trafficking in any part of its business or supply chains.
This is our ninth annual statement under the Act and provides an overview of our continuing commitment and development in this area.
Structure and Business
Manchester Metropolitan University is one of the largest campus-based universities in the UK, with a total student population of around 39,000, over 4,000 employees and an annual turnover of £422m in the 2022/23 financial year. Our campus is designed around the student experience and is based in the heart of Manchester, the UK’s most popular student city.
The University is arranged into:
- 4 Faculties - providing specialist learning and teaching, and
- Professional Services - providing a wide range of services and support to students and academic colleagues.
More information about us and our activities is available here: mmu.ac.uk
Supply Chains
In 2023 the University used over 3,722 suppliers to provide supplies, services, and works, ranging from micro and small medium enterprises (SMEs) through to large and multi-national enterprise organisations.
Business size & type:
41.3% of our suppliers are classed as microorganisations or SMEs, and 58.7% Large or Enterprise organisations.
Geographical distribution:
29.9% of our suppliers are based within Greater Manchester,
35.2% are based within the North-West of England,
90.4% are based in the UK, and
9.6% are non-UK based.
Policies
The University provides clear direction on its approach to the removal of modern slavery in its business and supply chains through our Modern Slavery Act Policy.
Due Diligence
Our Procurement Strategy and processes identify the standards and principles we require our suppliers to commit to and evidence as part of our supplier selection process, including Modern Slavery, Health & Safety, Sustainability, and our commitment to pay the Living Wage Foundation accredited rate.
Risk Assessment
The University recognises the risk that modern slavery increases as a supply chain extends and have identified four distinct levels:
1. our own operations and workforce
2. our Tier 1 (direct) suppliers
3. our Tier 2 (indirect) suppliers
4. our international partnerships
1. Our own operations and workforce
In respect of the University’s own operations, recruitment processes are robust and fair. The University recognises that in the case of internships there is a particular risk of exploitation and, to avoid this, the University ensures that those taking part are treated equally and remunerated in line with the Living Wage Foundation accredited rate. With regards to the employment of University staff, the University has several key HR policies which are relevant to the Modern Slavery Act. These include our Whistleblowing Policy, Respect at Work and Study Policy and Procedure and our Equality and Diversity Policy.
2. Our tier 1 (direct) suppliers
The University directly procures supplies, services and works from a wide range of suppliers across many categories and is committed to acquiring these in a responsible manner. Within our procurement processes, suppliers are required to demonstrate their commitment to the Modern Slavery Act as well as highlighting any areas of potential risk that may require further investigation/action. Before appointing Tier 1 suppliers, the University assesses the risk of modern slavery being present in the supply of the works, goods or services and challenges the supplier to identify, remove or reduce the risk wherever possible. Key risk areas include agency staff, services, construction and IT equipment.
• Agency staff
The University uses a range of external agencies to provide temporary staff to support its operations and is dependent upon the agencies, to have robust employment status and identification checks for the temporary workers who do not go through the Universities own employment checks, to ensure compliance with the Modern Slavery Act.
• Services
The University uses a range of suppliers to deliver services such as accommodation cleaning, grounds maintenance and waste removal. Often the work is seasonal or delivered over a short period of time and suppliers are required to have robust employment checks to ensure compliance with the Modern Slavery Act.
• Construction
When undertaking the procurement of building works, suppliers are asked specific questions during the tender process about their employment practices and the use of labour, to demonstrate compliance with the Modern Slavery Act.
• IT
The University is a member of Electronics Watch, an international independent monitoring organisation that assists public sector buyers to meet their responsibility to protect the human rights of electronics workers in global supply chains. IT hardware is purchased via consortia frameworks that require suppliers to commit to support Electronics Watch monitoring.
3. Our tier 2 (indirect) suppliers
Many of our suppliers have supply chains of their own and as part of the procurement and contract management process, we encourage our suppliers to:
• map their own supply chains and provide evidence of how they risk assess their supply chains.
• take appropriate actions where risks are identified.
• inform the Contract Manager of any findings of Modern Slavery identified in their organisation or in their supply chain.
4. Our international partnerships
The University has numerous academic partnerships with prestigious universities, colleges and academies around the world, and we are committed to ensuring that our expectations around Modern Slavery in our UK business is reflected in our international partnerships.
Training and Awareness
Training is a way of developing awareness and understanding of modern slavery and human trafficking amongst colleagues.
To support training the University has adopted a higher education focused online training module, which enables a higher level of understanding of how the risks of modern slavery and human trafficking may appear in our supply chains.
Effectiveness
Our contracted suppliers are vetted to ensure they are committed to supporting the principles of the Modern Slavery Act and have appropriate measures and policies in place.
All of our contracted suppliers with whom we spent >£100,000 in 2022/23 and are required to publish a statement under the Modern Slavery Act were found to be compliant.
Achievements 2022/23
During the last year we have achieved several positive outcomes in the fight against modern slavery and human trafficking, including:
• maintaining our membership of Slave Free Alliance (part of Hope for Justice).
• contributing to a Slave Free Hackathon event with our Operations and Supply Chain Management students, raising awareness and creating discussion.
• requiring our suppliers to pay the Living Wage Foundation accredited rate on our contracts.
• maintaining active membership with Electronics Watch.
• appointing our sports team kit suppliers following a Modern Slavery assessment, including factory audits and site visits with the Slave Free Alliance. (See Appendix 1)
• presenting a case study on the sports team kit procurement process to Finance and Sustainability colleagues to raise awareness.
• ensuring materials sourced from a tier 2 supplier on our Public Realm project were sourced from a quarry that demonstrated good working practices and aligned with the Ethical Trading Initiative code principles of:
• employment freely chosen
• freedom of association
• no use of child labour
• safe and hygienic working conditions (See Appendix 1)
Future Plans
Each year we reassess the effectiveness of the actions we have taken in the previous year to highlight modern slavery or human trafficking and use this assessment to develop our plans. In 2024 the University will:
• create opportunities to work with Academic colleagues on supply chain mapping e.g., University branded clothing.
• Include site visits with the Slave Free Alliance on targeted ‘high risk’ supply chains, e.g., promotional items.
• continue to identify modern slavery risks within our supply chains and act to remove these where possible, with the support of our suppliers and the Slave Free Alliance.
• review our Modern Slavery Policy and continue to develop our policies in line with good practice and procedures.
• raise the profile of Modern Slavery through training and awareness with stakeholders.
• Contribute to Electronics watch mobile phone supply chain transparency project.
• Develop a Supplier Code of Conduct with the Slave Free Alliance.
A. J. Hewitt
Chief Financial Officer
Date: 24 November 2023
Approved by the University’s Board of Governors
Date: 24 November 2023