成人直播 Modern Slavery and Human Trafficking Statement 2020
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act) and constitutes 成人直播鈥檚 (BU) modern slavery and human trafficking statement for the financial year ending 31st July 2020. This is BU鈥檚 fifth聽statement and previous statements remain available here.
BU鈥檚 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 general solvency of the institution. Its members are also BU鈥檚 charitable trustees. Further details about 成人直播鈥檚 structure and governance can be found on the BU website .
BU has聽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, the 成人直播 Business School, Faculty of Media and Communication, Faculty of Science and Technology 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 I.T 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鈥檚 students and student activities
During the 2019/20 financial year 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 during 2019/20 were impacted by the coronavirus pandemic. BU remains committed to raising awareness amongst its students and intends to resume on-campus events with partners in future years.
BU supply chains and supplier adherence to BU鈥檚 values
BU鈥檚 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. During the 2019/20 financial year, no concerns were raised under the Procedures. The Audit, Risk and Governance Committee has a standing agenda item to receive reports of any concerns raised under the Procedures and has oversight, along with the BU Board, of the Procedures. 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. During 2019/20 BU 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 Construction Policy, and Ethical Investment Policy.
To ensure that 成人直播 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 鈥淟ife Cycle Analysis鈥� Tool which is an agreed BU operational procedure under its ISO14001 standard for all procurements over 拢25,000. 聽Our supplier questionnaire for tenders above 拢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鈥檚 oversight of the implementation of the Sustainable Procurement and Ethical Investment Policies. The group will continue to operate and meet online (if necessary) during 2020/21.
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鈥檚 supply chains and its business.
BU鈥檚 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 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 2020/21 financial year.
Approval
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 成人直播 Board on 27聽November 2020