Statement on the Modern Slavery Act
Modern Slavery Act 2015
Introduction
The University recognises that modern slavery is a global issue and is committed to playing its part in supporting its eradication. This statement is published in accordance with the Modern Slavery Act (2015) (the Act) and has been approved by the Audit and Risk Assurance Committee through its delegated power from the Board of Governors. It sets out the steps taken by the University to prevent modern slavery and human trafficking in its business and supply chains.
The University's Ethics Statement states our commitment to the highest standards of ethical conduct in all our activities, along with making continuous improvements in this area. The University does not engage in, or condone, the practices of human trafficking, slavery or forced labour.
Business structures
The University is a Higher Education Corporation created by an instrument of government issued in April 1993 by the Privy Council. It is an exempt charity under the Charities Act 2011 and is registered with the Office for Students, the principal regulator for charity law purposes.
The Board of Governors is responsible for the strategic direction of the University. Our Vice-Chancellor has overall operational responsibility, supported by the Senior Leadership Team.
Academic Council is the senior consultative committee for academic matters, responsible for providing assurance to the Board and guidance to the Vice-Chancellor. Academic disciplines are organised into four faculties, led by Deans, divided into schools. There are four professional services directorates which includes a central procurement team based in the Finance, Human Resources and Infrastructure Directorate.
The University has two wholly owned subsidiaries: Kingston University Service Company Limited (KUSCO) which provides facilities management services; and Kingston University Campus Enterprises Limited which provides conference management services.
Supply chains
The University's supply chains mainly fall within the following 'top level' categories:
- Estates and Facilities Management (works, services and goods)
- ICT equipment and services
- Professional services
- Teaching materials
The University is a member of the London Universities Purchasing Consortium (LUPC) which has published its own Modern Slavery Statement and through whom the University has membership of Electronics Watch which works to protect the rights of electronics workers globally. Our membership of Electronics Watch via the LUPC means we can collaborate to minimise the risks of modern slavery.
In the 2022/23 financial year, the University undertook in excess of 16% of the value of our addressable spend through the LUPC and other collaborative agreements available to the public sector.
The particular business and supply chains which may pose particular risks in terms of slavery are in facilities management, ICT & AV equipment, construction, and partnerships with overseas institutions in some jurisdictions. Our due diligence processes (below) minimise these risks.
Due diligence and compliance
Our procurement process for new suppliers submitting UK level tenders, requires participants, through the standard selection questionnaire, to comply with the Act. We also use a supplier engagement tool (Net Positive Futures) to engage suppliers requesting that they review and confirm the arrangements they have in place to comply with the Act across their supply chains. All members of the procurement team have received training on use of the tool.
Through our involvement with the LUPC and other organisations, the team share and keep up-to-date with best practice to identify and assess risks within supply chains.
The University and its subsidiaries do not employ unpaid interns. KUSCO pays its employees the London Living Wage. All centrally-tendered contracts reiterate the University's commitment to fair work practices and paying the real living wage in line with the cost of living. We encourage our suppliers to do the same, pointing them to information about the real living wage.
Our standard terms and conditions of supply and other template agreements include binding obligations to comply with the Act.
The University's due diligence process for the validation of new institutional partners, and arising agreements, includes requirements for compliance with the Act.
All Modern Slavery Statements are published in our annual Financial Statements.
Policies
Our Corporate Social Responsibility Policy and Ethics Statement embeds Modern Slavery considerations, alongside other ethical business practices. They reflect our commitment to the highest standards of ethical conduct in all our activities, along with making continuous improvements in this area.
The University Guide to Good Research Practice incorporates reference to the Ethics Statement and Modern Slavery.
Our Procurement Policy has recently been updated further to include consideration of the requirements of the Act.
We encourage the reporting of concerns relating to Modern Slavery and human trafficking. Staff are encouraged to report concerns to their line manager in the first instance. If this is not feasible, or members of the University are unable to do so, concerns should be raised via our Whistleblowing Policy.
Work will continue during 2023/24 to ensure compliance with the Act.
October 2023
Contact us
Kingston University
Tel: +44 (0)20 8417 9000
Useful links
Contact us
Kingston University
Tel: +44 (0)20 8417 9000