Modern Slavery Act 2015 Statement

Purpose of the statement

The University of Glasgow has a zero-tolerance approach to slavery and human trafficking in all its forms.  This statement is made in pursuant to Section 54, Part 6 of the Modern Slavery Act 2015. This statement aims to inform the University of Court University of Glasgow, our staff, students and the general public about the steps taken during the last financial year, ending 31 July 2023 in support of the Modern Slavery Act 2015.

Statement

The University is committed to ensuring and actively monitoring that modern slavery and human trafficking are not taking place in any parts of its operations or its Supply Chain. 

Section 1 - Organisational Structure, Operations and Supply Chains

1.1 History

The University is the fourth oldest University in the English-speaking world. Founded in 1451, it has earned an international reputation for research innovation, for connecting with experts in global business, and for being the home of inspiring thinkers, including the father of economics, Adam Smith, to the eminent scientist, Lord Kelvin. In keeping with its historic legacy of changing the world, the University is a founding member of the elite Russell Group of 24 major UK research universities.

1.2 Principal operations

Study and research are grouped into four Colleges:

  • College of Arts & Humanities
  • College of Medical, Veterinary and Life Sciences
  • College of Science and Engineering
  • College of Social Sciences

The majority of operations are carried out on the University’s Gilmorehill campus in the West End of Glasgow. Finding community and strength within diversity, the University attracts students and academics from more than 150 countries around the globe. In addition, as a venue for international conferences and a hub of cultural interest, the University is also a major contributor to the cultural and commercial life of the country. 

1.3 World Changers Together: World Changing Glasgow 2025

The strategy responds to four major challenges facing higher education and wider society:

  • Building a sustainable future
  • Creating a fairer society
  • Reimagining the learning experience
  • Diversifying the student body

The University’s vision is to be The World-Changing University. Our purpose is transforming lives through ideas and actions. Our mission is to bring a community of world changers together.

The future holds innumerable challenges for our sector, our society and our world and we will have to adapt and change what we do and what we offer if we are to navigate these successfully. Our strategy and approach may evolve as the landscape changes, but our values will remain constant: 

  • Ambition & Excellence
  • Curiosity & Discovery
  • Integrity & Truth
  • An Inclusive Community

The strategy supports the long-term realisation of our vision by recognising the fundamental importance of a culture of open cooperation and is articulated across three themes: 

  • Community: people centered, globally engaged
  • Connectivity: collaboratively minded, digitally enhanced
  • Challenges: solution focused; impact oriented

Key to the realisation of our vision is our continuing success within the six strategic pillars of a world-changing University: 

  • World-Class Research
  • Outstanding Teaching
  • Lasting Impact
  • Global Perspective
  • Life-Changing Experiences
  • Inspiring People
The University of Glasgow's response to the Climate Emergency

The strategy outlines a route to net-zero carbon emissions for the organisation, by 2030. The University is committed not only to addressing its impacts on the environment, but also its impacts on people, communities and markets. As such, we have a well-developed approach to sustainable procurement.

We are fully cognisant of our responsibilities under the Modern Slavery Act 2015. Our Climate Change strategy commits us to use of the Ecovadis system for monitoring sustainability-related risks and driving improvements in our supply chain. We believe that use of Ecovadis helps us to ensure that modern slavery and human trafficking is not taking place in any parts of our operation, either within the University or our Supply Chain.

Further information on how our procurement processes support our commitments under the Modern Slavery Act 2015 can be found below.

1.4 Supply chains expenditure FY22/23

The University non-pay expenditure for FY22/23 was circa £390m, with £280m based on Core Trade spend.

We have identified 7 high risk category areas across circa 200 Suppliers that provide Goods, Services or Works.

Section 2 - Modern Slavery Policies

Governance Supporting The Modern Slavery Act 2015

2.1 Ethical Investment Policy

The University Court is committed to socially responsible investment. It does so by setting policy and via its Investment Advisory Committee (IAC) and its fund managers. IAC will require managers who undertake active investment on its behalf to properly consider Environmental Social and Governance (ESG) issues in their investment decisions. IAC will also require all managers to monitor the activities of companies with regard to ESG and to have a policy of engaging with companies on these issues to encourage positive changes.

It is the role of the University Court to set out the ethical platform on which the University’s asset investments are managed. The University’s approach is set out in the Policy on Socially Responsible Investment (SRI) – July 2021 which was approved by Court in October 2009 and updated in both 2018 and 2021. Court requires its investment managers to commit to socially responsible investment within their investment policies. The University also prohibits direct investment in the tobacco industry and in controversial armaments and, since 2014. In 2015, Court committed to a phased reduction in the University’s direct investment in the fossil fuel extraction industry and has in fact already achieved that goal.

2.2 Fundraising

Appointed by Senior Management Group (SMG), the Gift Acceptance Committee (GAC) ensures that gifts that are solicited and accepted by the University are consistent with our strategy and values and that all donors are treated equally. The GAC assesses whether they adhere to our Gift Acceptance Policy and the University’s core principles, values and strategic direction, and consider any potential ethical or reputational risk to the University that could arise from accepting a donation.

All single or cumulative gifts of £250,000 or more are taken to GAC for consideration. The GAC will retain oversight of all gifts under this level and reserves the right to consider any gift to the University regardless of size.

2.3 Human Resources Policy

The Human Resources Policies set out workplace rights at the University. Our Recruitment Policy ensures that rigorous Visa and Immigration procedures are in place to support right to work, skilled workers visa and global talent visa. All prospective employees or casual workers are required to undertake a Right to Work check confirming working permissions to ensure they have the appropriate right to work for the specific role and hours. Conducting a Right to Work check consists of documentation checks on every UK based employee and retaining it on their employee file.

The University always adheres to Immigration Rules and UKVI Policy in accordance with Home Office UKVI compliance. The University is supported by external recruitment agencies on collaborative Framework Agreements who are vetted through rigorous Procurement procedures.

The University of Glasgow is proud to be an Accredited Living Wage employer. This means: 

  • We are committed to paying all employees at least the Living Wage
  • We ensure that all casual workers engaged directly by the University are paid at least the Living Wage.

We have set up our procurement procedures to ensure that we engage with contractors and potential contractors to encourage them, as far as possible, to also pay the Living Wage to people regularly working on our premises. 

The University also champions broader fair work practices and has made the Scottish Business Pledge and, in partnership with our campus Trade Unions, published a jointly agreed Fair Work Statement encapsulating our commitment to a broader range of fair working practices in addition to paying the Living Wage.

2.4 Research And Partnerships

The University’s due diligence checks ensure that our Research funders and collaborating partners have an anti-slavery and human trafficking policy or equivalent in place. They are also required to verify that with regards to their recruitment and staffing procedures that they comply with local labour laws and the UK Modern Slavery Act 2015.

2.5 Procurement

The University’s Procurement Strategy outlines our ethical procurement approach and sets out our principles for the acquisition of Goods, Services and Works. We commit to procuring all Goods, Services and Works with high ethical standards and applying principles of sustainable procurement. Sustainable Procurement is a process whereby the University meets its needs for Goods, Services and Works in a way that achieves value for money (VFM) on a whole life cost basis, generating benefit not only to the University, but also with consideration to Social, Economic and Environmental factors.

The University Procurement Office’s role is to provide professional, qualified procurement expertise, advice and services; for all spend with external suppliers; in compliance with the Public Contract (Scotland) 2015 Regulations, the Procurement Reform Act 2014, the Procurement (Scotland) Regulation 2016 and any other Directives.

The Procurement Office has implemented the Advanced Procurement of University and Colleges (APUC) Supply Chain Code of Conduct. This focuses on the organisations and its Suppliers responsibilities in social, ethical, economic, and environmental areas across the Supply Chain. The University Procurement Strategy is committed to delivering our Sustainability Objectives, which include identifying modern slavery risks within our Supply Chain. Procurement has used the sustainability risk prioritisation tool (Marrakech) which assigns a score for each risk attached to a category of spend. The high-risk categories are then investigated using the DEFRA analysis tool. Thereafter Suppliers identified within these categories are measured and monitored through the EcoVadis Sustainability Rating Programme. This policy is a part of University’s Procurement Policy and Contracts and Supplier Relationship Management (CS&RM) Policy and is incorporated into all procurement and supply chain activities including tendering and contract procedure.

Section 3 - Risk Assessments and Due Diligence

This section details our understanding of the most significant modern slavery risks in the University of Glasgow supply chains and the modern slavery due diligence we have undertaken to identify and mitigate these risks.

3.1 High-Risk Supply Chain Category Areas

Our high-risk category areas of expenditure for FY22/23 were:

  1. Catering - £3m
  2. Construction - £95m
  3. Furniture – £4.8m
  4. Information Technology (IT) - £28.5m
  5. Laboratory - £26.1m
  6. Travel - £13.7m
  7. Utilities - £15.4m

3.2 Assessing Risk and Identifying High Risk Categories

The University of Glasgow has selected EcoVadis to simplify collaboration with our external Suppliers in order to assess their sustainability / Corporate Social Responsibility (CSR) performance worldwide. We rely on EcoVadis’ CSR expertise to produce ratings and detailed scorecards that make it easy for the University and the Supplier to understand their CSR performance, and to work together if any improvements are needed. As an internationally recognised standard, EcoVadis sustainability ratings provide global benchmarks, which are essential for measuring and improving the performance of our global supply chain. The EcoVadis rating is based on an evidence-based assessment, adapted to hundreds of business categories, takes into account relevant industry labels and certifications as well as local laws in 150 countries, and is aligned with global standards like the UN Global Compact.

The EcoVadis assessment is an evaluation on how well a company has integrated the principles of Corporate Social Responsibility into their business and management system. It is based on the following founding principles:

  • Evidence Based
  • Industry sector, country and size taken into account
  • Assessment by experienced CSR experts
  • Traceability & Transparency of documentation
  • Excellence through continuous improvement

EcoVadis has a comprehensive scoring criterion for each Supplier, see figure 1. Under the labour & Human Rights pillar, assesses the Suppliers compliance to the Modern Slavery Act 2015 statement, see figure 1.

Figure 1A Robust Methodology table - 21 CSR criteria covered

After assessment, EcoVadis provide the Supplier and the University full access to their sustainability rating through their online portal. This details area of strength and areas on where improvement is required. The Supplier assessments are reviewed on an annual basis. Figure 2 is an example of a Suppliers sustainability scorecard.

Figure 2

Ecovadis dashboard screen

3.3 Supply Chain Expenditure

The University has a non-pay expenditure of c£390m of which is c£280m core trade spend across Goods, Services and Works. The sustainability risk prioritisation tool (Marrakech) and the DEFRA analysis tool review have identified 7 high risk category areas in relation to Modern Slavery as listed below:

  1. Catering
  2. Furniture
  3. Utilities
  4. IT
  5. Labs
  6. Travel
  7. Construction

3.4 Procurement Outcomes

The current expenditure across the 7 high risk categories is c£192m, with 198 Suppliers. The number of Suppliers that have completed their EcoVadis assessment is 101, with an expenditure of £152m. This results in 79% of the expenditure identified across the 7 high risk categories as having an EcoVadis sustainability rating, see figure 3. The Procurement Office are continually working with our external Suppliers and EcoVadis and there are a further 40 Suppliers going through this assessment process.

Figure 3

University of Glasgow spend = £390m (FY22-23)
Core Trade Spend = £280m (FY22-23)
Identified High Priority Sustainability Spend = £192m
Actual EcoVadis Rated Spend = £152m
Category FY22-23
Priority Supplier Expenditure		 EcoVadis Rated Expenditure High Priority Sustainability Spend % No. of High Risk Suppliers No of EcoVadis Rated Suppliers
  £192,166,334 £152,639,168 79% 198 101
1. Catering Priority 1,2,3  Catering
EcoVadis Rated Expenditure		 Sustainability Mapping Priority 1,2&3 No. of Suppliers No.of EcoVadis Rated Suppliers
£3,012,607 £247,053 8% 46 5
2. Furniture Priority 1,2,3  Furniture
EcoVadis Rated Expenditure		 Sustainability Mapping Priority 1,2&3 No. of Suppliers No.of EcoVadis Rated Suppliers
£4,782,804 £4,551,075 95% 9 4
3. Utilities Priority 1,2,3  Utilities
 EcoVadis
Rated Expenditure		 Sustainability Mapping Priority 1,2&3 No. of Suppliers No.of EcoVadis Rated Suppliers
£15,440,761 £3,377,525 22% 4 2
4. IT  Priority 1,2,3  IT
EcoVadis Rated Expenditure		 Sustainability Mapping Priority 1,2&3 No. of Suppliers No.of EcoVadis Rated Suppliers
£28,591,921 £20,932,548 73% 29 20
5. Labs Priority 1,2,3  Labs
EcoVadis Rated Expenditure		 Sustainability Mapping Priority 1,2&3 No. of Suppliers No.of EcoVadis Rated Suppliers
£26,133,481 £11,964,972 46% 49 25
6. Travel Priority 1,2,3  Travel
EcoVadis Rated Expenditure		 Sustainability Mapping Priority 1,2&3 No. of Suppliers No.of EcoVadis Rated Suppliers
£13,784,828 £12,927,038 94% 10 1
7. Construction Priority 1,2,3  Construction
EcoVadis Rated Expenditure		 Sustainability Mapping Priority 1,2&3 No. of Suppliers No.of EcoVadis Rated Suppliers
£94,834,920 £93,053,945 98% 35 28
8. Other Priority 1,2,3  Construction
EcoVadis Rated Expenditure		 Sustainability Mapping Priority 1,2&3 No. of Suppliers No.of EcoVadis Rated Suppliers
£5,585,013 £5,585,013 100% 16 16

Section 4 - Training and Awareness Raising

4.1 Training and Awareness

Sustainable Procurement training has been completed by all members of the Procurement team.  All staff and students can improve their awareness, knowledge and understanding through the various Modern Slavery training courses.

4.2 Awards

CIPS Procurement Excellence Standard Award

The University has held the Chartered Institute of Procurement and Supply (CIPS) Certification since 2015 and has recently been revalidated and achieved the Procurement Excellence Standard Award Number 0660 valid until 04/2025. This is an in-depth assessment process that measures the organisation’s procurement function against world-class standards.

4.3 Living Wage Employer

The University of Glasgow is proud to be an Accredited Living Wage employer. 

4.4 Electronics Watch

The University is a member of Electronics Watch, which is an independent monitoring organisation that assists public sector buyers to meet their responsibility to protect the labour rights of workers in their global electronics supply chains more effectively and less expensively than any single public sector buyer could accomplish on its own.

CIPS Procurement Excellence logo, Living Wage logo & Electronics Watch logo

Section 5 - Goals and KPIs

This section lists all of the goals and KPIs listed in this statement.

We have set these goals to ensure we make year-on-year progress and established key performance indicators to measure the effectiveness of our efforts to protect workers from exploitation.

  • Continue to ensure that the University has adequate governance supporting The Modern Slavery Act 2015.
  • Continue to use EcoVadis to assess our high-risk Suppliers Corporate Social Responsibility performance to ensure modern slavery is not happening in our supply chain.
  • Ensure all high-risk Supplier sign up to the University Supplier Code of Conduct.
  • Sustainability and Sustainable Procurement Practices – embed socially responsible procurement.
  • Procure from Contracts that are issued on the University Terms and Conditions with compliance to relevant laws and regulations.
  • Engage and ensure our Suppliers follow Modern Slavery compliance.
  • Positive engagement and collaboration with others such as APUC, Electronic Watch, EcoVadis and other centers of excellence within the UK.
  • Report on known modern slavery cases in our direct area of influence.
  • Resolve all known reported cases, which are currently none.
  • Revalid FairTrade status.

Release Date: January 2024
Author: Head of Procurement
Approver: David Duncan on behalf of Court
Title: Chief Operating Officer and University Secretary