Bournemouth University Modern Slavery and Human Trafficking Statement 2021
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act) and constitutes Bournemouth University’s (BU) modern slavery and human trafficking statement for the financial year ending 31st July 2021. This is BU’s sixth statement and previous statements remain available here.
BU’s organisational structure
BU is a higher education provider created by statute and is an exempt charity. BU is responsible to the Office for Students (OfS) as principal regulator for Higher Education Institutions in England that are exempt charities. The BU Board oversees the strategic development of BU and ensures the effective use of resources and the solvency of the institution. Its members are also BU’s charitable trustees. Further details about BU’s structure and governance can be found on the BU website here.
BU has undergraduate and postgraduate students who are attracted to BU from all over the world. BU is organised into several Faculties comprising; the Faculty of Health and Social Sciences, Faculty of Media and Communication, Faculty of Science and Technology, the Bournemouth University Business School and also the BU Doctoral College. BU also has several professional service departments which include, amongst others; Finance, Academic Services, Estates, Marketing and Communications, Human Resources and Organisational Development, Student Services and IT Services.
BU has three wholly owned subsidiary companies; BU Innovations Limited, BU Foundation Limited and BU Community Business Limited. BU also undertakes collaborative work and enters into academic partnerships with other research organisations and business around the world.
BU’s student and staff activities
During the 2019/20 and 2020/21 financial years BU had hoped to build upon its student focused anti-slavery activities, such as the successful 2018 Anti-Slavery Student Ambassador (ASSA) training day, but our plans for on-campus events have continued to be impacted by the coronavirus pandemic. BU has a staff member on the CPS Wessex Modern Slavery Scrutiny Panel which reviews human trafficking and modern slavery cases across the region. BU remains committed to raising awareness amongst its students and staff and intends to resume on-campus events with partners in future years.
BU supply chains and supplier adherence to BU’s values
BU’s supply chains for goods and services are complex and multi-tiered, and span from individuals to national and international entities. BU conducts an annual risk assessment to help focus our activity and the following supply chains continue to be viewed as high risk areas; security services, construction/ estates goods and services, catering/ food supply chains, cleaning/ domestic services, ICT equipment/ general electronics and clothing/textiles.
BU continues to seek assurances from suppliers and contractors of their compliance with the Act via our tender procedures, by contacting key suppliers in the higher risk areas, reviewing contracts with suppliers in light of the need to prevent modern slavery and having Modern Slavery Act 2015 clauses in our BU standard terms of business for procurement and other supplier contracts.
BU policies and due diligence processes
BU implemented Anti-Slavery and Human Trafficking Policy and Procedures in 2016 which provide a reporting mechanism for all staff to raise concerns. The Policy and Procedures are formally reviewed and approved at least every two years and were most recently considered by the Audit, Risk and Governance Committee on behalf of the Board in November 2021. The Audit, Risk and Governance Committee has a standing agenda item to receive reports of any concerns raised under the Policy and Procedures and has oversight, along with the BU Board, of compliance with the Policy and Procedures. During the 2020/21 financial year one report was received of an allegation of modern slavery in BU’s supply chain which the Chief Operating Officer reported to the Audit, Risk and Governance Committee and sought further information on. On investigation it was confirmed that the issue did not constitute modern slavery. The BU Whistleblowing (Disclosure in the Public Interest) Policy also protects staff, students and anyone working for BU (including casual workers, self-employed contractors, agency personnel) and allows them to raise concerns related to modern slavery or risk of modern slavery.
BU continues to mitigate the risk of modern slavery and human trafficking within its own staff community by following fair HR recruitment and selection policies and procedures. Where recruitment agencies are used, BU requires that such agencies comply with all UK legislation relating to the employment rights and welfare of candidates. BU has prioritised the health and safety of its staff and students during the pandemic, ensuring that our campuses are COVID-secure and assisting those who are self-isolating. BU has also made sure that staff and students are still able to access grievance procedures and raise concerns whilst working remotely.
BU has a number of frameworks which underpin its ethical standards across all of its business activities. BU has also remained committed to playing its part in delivering the UN Sustainable Development Goals and worked to further embed the UN SDGs into all areas of BU. BU also continued to apply the following policies to ensure the procurement of goods and services took account of their social impact and to achieve ethical standards of business conduct; Sustainable Procurement Policy, Sustainable Food Policy, Fair Trade Policy, Sustainability Policy, Sustainable IT Policy and Sustainable Construction Policy. BU also has an Ethical Investment Policy in which slavery and child labour are identified as areas in which investment is deemed inappropriate.
To ensure that BU takes full account of the economic, social and environmental implications of the goods, works and services it buys from external suppliers and organisations, BU continued to use a “Life Cycle Analysis” Tool which is an agreed BU operational procedure under its ISO14001 standard for all procurements over £25,000. Our supplier questionnaire for tenders above £25,000 also has a specific section in relation to compliance with the Act.
BU also continued to procure goods and services via consortium frameworks such as the Crown Commercial Service (CCS) and through its membership of the Southern Universities Procurement Consortium (SUPC) which is a membership-based buying organisation for universities and further education colleges.
Training and Raising Awareness
BU has dedicated representatives who are aware of the requirements of the Act from Legal Services and Corporate Governance, Human Resources, Procurement and Sustainability. During 2019/20 BU set up an Ethical/Responsible Procurement Group where slave labour matters are considered under the group’s oversight of the implementation of the Sustainable Procurement and Ethical Investment Policies. The group will continue to operate and meet online (if necessary) during 2021/22.
BU remains committed to working with local charities and organisations to raise awareness in the community and will return to a programme of events when other pressures caused by the pandemic reduce.
As part of internal and external training sessions, BU ensures that relevant staff members are made aware of the risks of modern slavery and human trafficking in BU’s supply chains and its business.
BU’s effectiveness in combating slavery and human trafficking
BU will continue to review the effectiveness of its measures taken to combat slavery and human trafficking on a periodic basis and will review its approach against the new legislative measures expected from the Government following the transparency in supply chains consultation.
BU will continue to monitor how the challenges of the pandemic impacts on our ability to identify and address risks of modern slavery in our operations and supply chains. BU will take such action as deemed necessary to maintain the highest levels of ethical and human rights principles in its business conduct and will monitor any emerging or heightened risks the pandemic may cause during the 2021/22 financial year.
This statement has been approved by the BU Board who, together with the Audit, Risk and Governance (ARG) Committee, will review and update it as necessary on an annual basis.
Approved by the Bournemouth University Board on 26 November 2021