skip to content

Registrary's Office

 

Anti-slavery and anti-trafficking statement and policy

23 July 2018

The University Council has approved a statement and policy affirming the University’s commitment to combatting slavery and human trafficking, in accordance with Section 54(1) of the Modern Slavery Act 2015.


Anti-slavery and anti-trafficking statement for the financial year ending 31 July 2017

(pursuant to Section 54(1) of the Modern Slavery Act 2015)

The University of Cambridge is a common law corporation and is an exempt charity under the Charites Act 2011. The University consists of academic Schools, Faculties and Departments, libraries and other collections, administrative departments and, for the purposes of this statement, includes its wholly owned companies. Its mission is to contribute to society through the pursuit of education, learning, and research at the highest international levels of excellence.

The University is committed to combatting slavery and human trafficking and to acting with integrity in all its relationships. It has implemented an Anti-slavery and Anti-trafficking Policy reflecting this commitment (published below). To ensure compliance with this commitment, the University has revised its standard procurement and contract documentation which now contain warranties to this effect which suppliers and contractors must accept wherever possible. The University’s dignity@work, equal opportunities, and whistleblowing policies are additional mechanisms which support the combat of modern slavery (see http://www.hr.admin.cam.ac.uk/policies-procedures).

Although committed to carrying out proper due diligence, as a higher education institution the University considers the risk of modern slavery to be low due to the nature of its limited supply chains apart from Cambridge University Press, a department of the University providing publishing services, which has different supply chains and has consequently developed its own anti-slavery measures (see http://www.cambridge.org/about-us/legal-notices/anti-slavery-and-human-trafficking/).

The University has not received any reports of instances of modern slavery over the past financial year but will continue to raise awareness of modern slavery and of the need for proper due diligence and risk assessment processes to be applied by staff and suppliers, in accordance with its policy.

This annual statement was approved by the Council on 23 July 2018.


Anti-slavery and anti-trafficking policy

Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as enacted in the Modern Slavery Act 2015 (‘the Act’). The University is committed to a zero tolerance approach to modern slavery and to acting with integrity in all its dealings, relationships, and supply chains. It expects the same high standards from all its staff, suppliers, contractors, and those with whom it does business. This policy applies to all employees, workers, consultants, and other persons doing business with the University including all its wholly owned companies, contractors, and suppliers.

The University acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour. Although the University as a higher education institution[1] considers the risk of modern slavery to be low due to the nature of its supply chains, it takes its responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following policy measures:

  • The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for the University or under its control.
  • Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).
  • All supply chain lines need to be continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited.
  • The University encourages anyone to raise any concerns about modern slavery and will support anyone who acts in good faith. The University has a whistleblowing policy which can be used to report any instances of modern slavery, which was updated in 2017 (https://www.admin.cam.ac.uk/offices/hr/policy/whistleblowing.html).
  • The University has dignity@work and equal opportunities policies (see http://www.hr.admin.cam.ac.uk/policies-procedures) and is committed to upholding human rights.
  • The University’s Anti-slavery and Anti-trafficking Statement is published annually on the Registrary’s Office website [above].
  • The University will continue to develop its commitment to combat modern slavery and will provide staff training where appropriate.

In relation to the University’s procurement activities, the following actions have been implemented in 2017–18 or are in the process of being implemented, for completion in 2018–19:

  1. Amendments to the trade supplier portal (Intend) to question potential new suppliers on their compliance with the Act. The obligation will be on potential new suppliers to confirm their compliance; failure to confirm compliance will result in exclusion from the list of approved trade suppliers. 
  2. Review and updating of all procurement documentation to include references to the Act.
  3. Amendments to the trade supplier approval process so that the University’s Procurement Office reviews all new and amended suppliers and re-activation requests, with confirmation of compliance recorded as part of that process.
  4. Provision of information on the obligations under the Act to Departments, Faculties and other institutions using existing communication channels.
  5. Development of an online training tool on the Act, to be included in the induction materials for new employees and as part of ongoing training for existing employees.
  6. Development and circulation of a questionnaire on compliance to trade suppliers.

Any breaches of this policy may result in the University taking disciplinary action against individual(s) and/or terminating its relationship with any organization or supplier.

This policy is managed by the Registrary’s Office and was approved by the Council on 23 July 2018.

 


[1]  Cambridge University Press, a department of the University providing publishing services, has different supply chains and has consequently developed its own anti-slavery measures; see http://www.cambridge.org/about-us/legal-notices/anti-slavery-and-human-trafficking/. Cambridge Assessment has its own policies on whistleblowing, on equality and dignity at work, and its own procurement procedures.