Annual Modern Slavery and Human Trafficking Statement 2022/2023

Introduction

1. Introduction 

This statement is issued by the Chair of Council for the University of Wales Trinity Saint David  (UWTSD) and University of Wales (UW), and the Chair of the Board of Coleg Sir Gâr (CSG)  pursuant to section 54(1) 3. of the Modern Slavery Act 2015 and constitutes the UWTSD Group’s Slavery and Human Trafficking Statement for the financial year ending 31 July 2023. In addition,  this statement sets out the UWTSD Group’s undertakings in respect of the Welsh Government  Code of Practice on Ethical Employment in Supply Chains, to which the UWTSD Group has committed its support. The Group has identified a number of actions within the 12 commitments  which is linked to its Procurement Policy. 

The Modern Slavery Act 2015 recognises that modern slavery is a crime and a violation of  fundamental human rights. It takes 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 in order to exploit them for personal or commercial gain. 

2. Group Structure 

  • The University of Wales Trinity Saint David (hereinafter referred to as “UWTSD”) is one of eight Higher Education (HE) institutions in Wales (not including the Open University in Wales) and has a total student population of over 28,000 (both Further and Higher Education). 

    The University was formed on 18 November 2010 through the merger of the University of Wales Lampeter and Trinity University College Carmarthen, under Lampeter’s Royal Charter of 1828.  On the 1 August 2013, Swansea Metropolitan University became part of UWTSD. 

    UWTSD is part of a Group structure which offers both Higher and Further Education and includes  Coleg Sir Gâr (CSG) and Coleg Ceredigion. CSG became a subsidiary company of UWTSD in  2013 and Coleg Ceredigion became a subsidiary company of CSG in 2017. The Group offers a  range of integrated pathways from year 10 upwards and has delivered transformational change  for the region. 

    The University’s annual turnover in the period covered by this report was £131.6m. . 

  • The University of Wales (hereinafter referred to as “UW”) was formed under a Royal Charter in  1893. In August 2017 UW and UWTSD entered into a legal deed. In signing the deed, the  governing bodies of both institutions resolved to have joint governance and administrative  arrangements to operate in a combined way subject to their respective Royal Charters and law.  The operational and administrative functions and policies referred to in this policy are therefore  applicable to both institutions, including where UWTSD is the lead institution or the signatory. 

    In the period covered by this report UW had an annual turnover of £2.7m. 

  • Coleg Sir Gâr is a large, multi-campus, further education college. It has approximately 9,200  learners of which some 3,200 are full-time, over 6,000 are part-time. There are approximately  750 higher education learners. The College is based in South West Wales and has five main  campuses at Llanelli (Graig), Carmarthen (Pibwrlwyd and Jobs Well), Ammanford and Llandeilo  (Gelli Aur). Campuses vary in size and nature and most offer a variety of subjects.

    The College has an annual turnover of £45.7m and employs approximately 648 staff. Of these, approximately 299 are directly involved in teaching and 349 in support and administrative  functions. 

  • Incorporated in 1993 following the amalgamation of four Further Education Institutions across Ceredigion, Coleg Ceredigion is the largest provider of FE provision in Ceredigion with a broad  curriculum base. 

    Based on two main sites of 8,800m2, with approximately 131 staff, of whom around 64 are employed on a full-time basis The College provides education and training to the local  community, and has an annual turnover of £6.7m. For the academic year 2022/23 there were  1,300 learners at the college.

3. Supply Chains 

The UWTSD Group purchases many of its goods and services from public sector purchasing consortia. The principal consortia are: 

  • National Procurement Service (NPS); 
  • Higher Education Purchasing Consortium for Wales (HEPCW);  
  • Crescent Purchasing Consortium (CPC);  
  • Crown Commercial Services (CCS). 

The UWTSD Group and the consortia are developing processes to manage supply chain risks relating to slavery and human trafficking. 

The joint contracting programme provides a comprehensive and mature collaborative portfolio, which includes some of the high risk categories. 

Many of UWTSD Group’s suppliers in these higher-risk categories have committed to the Base  Code of the Ethical Trading Initiative (ETI) and the UK Universities Purchasing Consortia are working to persuade the remaining suppliers in these categories to join them. The ETI Base Code is founded on the conventions of the International Labour Organisation (ILO) and is an internationally recognised code of labour practice, requiring that: 

  1. Employment is freely chosen; 
  2. Freedom of association and the right to collective bargaining are respected; 3. Working conditions are safe and hygienic; 
  3. Child labour shall not be used; 
  4. Living wages are paid; 
  5. Working hours are not excessive; 
  6. No discrimination is practised; 
  7. Regular employment is provided; and 
  8. No harsh or inhumane treatment is allowed. 

During the year to July 2023 the UWTSD Group acted responsibly to ensure compliance with the Modern Slavery Act 2015. The Group is committed to working towards ensuring there is no  modern slavery or human trafficking in its supply chains or in any part of its organisational  business. In light of the requirement to report on measures to ensure all parts of business and  supply chain are slavery free, the Group will continue to review workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues. The publication of  this statement is also a requirement of the Welsh Government Ethical Employment in Supply  Chains Code of Practice, which the UWTSD Group is committed to, and became a signatory to  alongside all Welsh universities in July 2017. The UWTSD Group is working towards achievement of the commitments of the Code of Practice (Appendix 1), which includes  encouraging suppliers to adopt the Code. 

4. Policies and Procedures 

The UWTSD Group’s Procurement Strategy includes the principles of the Modern Slavery Act  2015 and the Ethical Employment in Supply Chains. The Procurement Strategy demonstrates commitment to acting ethically and with integrity in all organisational business relationships to  ensure slavery and human trafficking is not taking place within our supply chains. 

Workplace and Study policies and procedures are reviewed regularly to ensure they reflect the 12 Code of practice commitments (Appendix 1). 

The University has a Safeguarding Forum which oversees policies relating to the safeguarding of its students, a representative from Coleg Sir Gâr/Coleg Ceredigion attends  this forum. 

5. Due Diligence 

As part of our commitment to identify and mitigate risk we will put in place systems to: 

  • Identify and assess potential risk areas in the our supply chain 
  • Mitigate the risk of slavery and human trafficking occurring in our supply chain • Monitor potential risk areas in our supply chain 
  • Protect whistle-blowers 

6. Training 

The UWTSD Group’s procurement staff have undertaken an e-learning module regarding modern slavery and ethical employment, and it is a mandatory training requirement, as key legislation,  for all UWTSD staff. 

7. Ongoing Support 

The UWTSD Group is committed to better understanding its supply chains and working towards greater transparency and responsibility towards people engaged within them. 

For contracts awarded and participated in, UWTSD will identify those supply chains which  represent a medium to high risk of modern slavery, human trafficking, forced and bonded labour,  and labour rights violations. Working with suppliers, collaborative purchasing groups and other  relevant organisations, UWTSD will closely monitor those supply chains that have been identified  as a potential risk and take appropriate action if necessary.

Appendix 1 – Welsh Government Code of Practice Commitments Ethical Employment in Supply Chains 

  • Our organisation will: 

    1. Produce a written policy on ethical  employment within our own organisation  and our supply chains. Once produced we  will communicate the policy throughout our  organisation and we will review it annually and monitor its effectiveness. As part of this  we will:
      1. Appoint an Anti-Slavery and Ethical  Employment Champion.

    1. Produce a written policy on  whistleblowing to empower staff to raise  suspicions of unlawful and unethical  employment practices, and which places a  responsibility on staff to report criminal  activity taking place within our own  organisation and our supply chains. Once  produced we will communicate the policy  throughout our organisation. We will review  the policy annually and monitor its  effectiveness.  We will also:
    2. Provide a mechanism for people  outside our organisation to raise  suspicions of unlawful and unethical  employment practices.

  • Ensure that those involved in buying/  procurement and the recruitment and  deployment of workers, receive training on  modern slavery and ethical employment  practices, and keep a record of those that  have been trained.

  • Ensure that employment practices are  considered as part of the procurement process. We will: 

    1. Include a copy of our Policy on ethical employment (Commitment 1) in all  procurement documentation. 
    2. Include appropriate questions on ethical employment in tenders and assess  the responses provided. 
    3. Incorporate, where appropriate, elements of the Code as conditions of  contract.
    4. Ask bidders to explain the impact  that low costs may have on their workers each time an abnormally low quote or  tender is received.

  • Ensure that the way in which we work  with our suppliers does not contribute to the use of illegal or unethical employment practices within the supply chain. We will: 

    1. Ensure that undue cost and time pressures are not applied to any of our  suppliers if this is likely to result in unethical  treatment of workers. 
    2. Ensure that our suppliers are paid on  time – within 30 days of receipt of a valid  invoice.

  • Expect our suppliers to sign up to this  Code of Practice to help ensure that ethical  employment practices are carried out  throughout the supply chain.

  • Assess our expenditure to identify and  address issues of modern slavery, human rights abuses and unethical employment practice. We will: 

    1. 7.1 Carry out regular reviews of expenditure  and undertake a risk assessment on the findings, to identify products and/or services  where there is a risk of modern slavery and/or  illegal or unethical employment practices within the UK and overseas.
    2. Investigate any supplier identified as high  risk, by direct engagement with workers wherever possible.
    3. Work with our suppliers to rectify any  issues of illegal or unethical employment  practice.
    4. Monitor the employment practices of  our high risk suppliers, making this a standard  agenda item for all contract management  meetings/reviews.

  • Ensure that false self-employment is not  undertaken and that umbrella schemes and  zero hours contracts are not used unfairly or  as a means to: 

    1. Avoid, or facilitate avoidance of, the  payment of tax and National Insurance  contributions and the relevant minimum  wages. 
    2. Unduly disadvantage workers in terms of  pay and employment rights, job security and  career opportunities. 
    3. Avoid Health and Safety responsibilities.

  • Ensure that workers are free to join a  Trade Union or collective agreement and to  undertake any related activity and raise worker concerns without risk of discrimination. We will: 

    1. Not make use of blacklists / prohibited lists. 
    2. Ensure that our suppliers do not make  use of blacklists/prohibited lists.
    3. Not contract with any supplier that has  made use of a blacklist/prohibited list and failed to take steps to put matters right.
    4. Expect our suppliers to ensure that  Trade Union representatives can access  members and contracted workers. 

  • Consider paying all staff the Living  Wage Foundation’s Living Wage as a  minimum and encourage our suppliers to  do the same. 

    We will: 

    1. Consider paying at least the Living  Wage Foundation’s Living Wage to all our  staff in the UK. 
    2. Consider becoming an accredited  Living Wage Employer.
    3. Encourage our suppliers based  overseas to pay a fair wage to all staff, and to ensure that staff working in the UK  are paid at least the minimum wage.

  • Produce an annual written statement  outlining the steps taken during the financial year, and plans for future  actions, to ensure that slavery and human  trafficking are not taking place in any part  of our organisation and its supply chains. We will: 

    1. Ensure that the statement is signed  off at senior management/board level.
    2. Publish the statement on our  website. If this is not possible, we will  provide a copy to anyone within 30 days  of a request being made. All organisations  signing up to this Code are expected to  produce and publish this annual written  statement – for commercial organisations with a turnover of £36m or more, this also  fulfils the requirements of Section 54 of  the Modern Slavery Act 2015. 

    We encourage all organisations to publish their statements on the Transparency in  Supply Chains (TISC) register  

    www.tiscreport.org free of charge for all  public and small organisations. In  exchange, they can make use of the  Wales Antislavery Logo.

  • For Public sector to whom the Code of Practice on Workforce Matters (2014)  applies: 

    Ensure all those undertaking work on  an outsourced contract are treated fairly and equally. We will: 

    1. 12.1 Ensure that public sector staff  who are transferred as part of a public  service which is outsourced to a third party retain their terms and conditions of  employment.
    2. Ensure that other staff working  on an outsourced public service are  employed on terms and conditions that are comparable to the transferred public  sector staff.