Modern Slavery and Human Trafficking Statement

Modern Slavery and Human Trafficking Statement 2023/2024

Introduction and Purpose of the Statement

This statement is made pursuant to section 54 (Part 6) of the Modern Slavery Act 2015 and is intended to inform College staff, students and the general public of the steps taken by Glasgow Clyde College during the financial year ending 31^st July 2024 in relation to its obligations to mitigate the risk of slavery and human trafficking in any of its business activities.

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.

Glasgow Clyde College recognises that it has a responsibility to take a robust approach to slavery and human trafficking. This statement, produced annually, intends to demonstrate the College’s progressive approach in actions and commitment to understanding potential Modern Slavery risks related to its activities and to minimise the risk of slavery and human trafficking in its supply chains.

Glasgow Clyde College

Glasgow Clyde College is a charitable body, registered in Scotland, with registration number SC021182. The College’s Strategic Plan 2022-2025 Releasing Potential with the College Mission of “Inspirational Learning; Changing Lives”. The Plan outlines our vision as follows:

“By 2025 Glasgow Clyde College will be celebrated as a socially progressive College which is relentlessly focussed on improving the prosperity of the communities it serves. The College will be acknowledged for its unrivalled ‘career ready’ students, employment focused curriculum, pioneering approaches, financial resilience and members of staff who are passionate in their pursuit of excellence. Glasgow Clyde College will be the partner of choice for employers, the employer of choice for members of staff and the College of choice for our communities.”

The College’s values capture our ethos: who we are, what we believe in and what we stand for. Our values set out how we conduct ourselves, how we expect to be treated as part of Glasgow Clyde and how we engage with our partners. In delivering our Strategic Plan, and how we act and make decisions guided by these values:

People-centred

We are unwavering in our expectation that we conduct ourselves in a manner which is open, respectful and with uppermost integrity. The needs and interests of our students, colleagues and stakeholders will be at the forefront of all decision-making.

Pioneering

We are restless in our desire to be innovative, ambitious, forward-thinking and courageous in the pursuit of creating an unrivalled inspirational learning experience and work environment.

Principled

We are determined to ensure that fairness, equality and inclusivity are embedded into the heart of the College and guide everything we do.

Passionate

We are relentless and tenacious in our ambition to inspire students and colleagues to achieve their potential, change their lives and support them to overcome the barriers to doing so.

The College has a zero-tolerance policy in relation to modern slavery and human trafficking. We are committed to conducting all business dealings and relationships in an ethical and transparent manner, and to implementing and enforcing effective systems and checks to ensure the College is not contributing to modern slavery in any way.

Statement and Commitment

The College is committed to ensuring that modern slavery and human trafficking is not taking place in any part of its operation within the College and its supply chain. We are committed to protecting and respecting human rights across the College’s activities and will take reasonable and appropriate steps to influence others to ensure slavery and human trafficking is not taking place, where it is possible to do so.

The College is accredited by the Living Wage Foundation, which certifies that all staff are paid the real living wage. Non College contracted workers that regularly work onsite at the College are expected to be paid the UK living wage as defined by the Living Wage Foundation, and the College evaluates suppliers’ approach to Fair Work First including the Living Wage, in line with the Scottish Government’s Procurement Reform (Scotland) Act 2014: statutory guidance - gov.scot (www.gov.scot).

The College’s Procurement Strategy outlines our principles and approach to ensuring ethical procurement, fairly and ethically produced products and fair working practices, including promoting payment of the Scottish real Living Wage.

Supply Chain Expenditure

The College has a non-pay annual expenditure of approximately £10m across Goods, Services and Works. Our supply chains fall under the following main categories:

Estates Goods and Services
ICT Equipment and Services
Professional Services
Library Resources
Laboratory Consumables and Equipment
Human Resources

The principal categories, which carry risks, are office supplies, laboratory consumables, ICT equipment and some estates services, such as cleaning, waste and security services.

Procurement Support for the Modern Slavery Act 2015

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Measures included within the Public Contracts (Scotland) Regulations 2015 are embedded in all of our procurement activities and relevant Scottish Procurement Policy Notes (SPPN 3/2020) are circulated to relevant staff and implemented where required.

The College is a member of the Advanced Procurement for Universities and Colleges (APUC) consortium, and therefore endorses the APUC Sustain supply chain code of conduct, which specifies that suppliers shall not use forced, involuntary or underage labour.

APUC is actively involved in several cross-sector initiatives related to addressing modern slavery risks in supply chains. This includes the HEPA (Higher Education Procurement Academy) responsible procurement group, the UKUPC Responsible Procurement Network, the International Working Group on Ethical Public Procurement, and Electronics Watch.

Identifying and Mitigating Potential Risk in Our Supply Chains

The risk of Modern Slavery in the College’s direct and local activities is considered low. However, we recognise the potential risks linked to the supply chain of goods and services we buy across the world. A large portion of these goods are bought through collaborative contracts, and we work with the relevant bodies to ensure anti-corruption activities are addressed during their procurement processes as well as in our own.

During 2021, the College as part of the Scottish Higher and Further Education Sector have contracted with a company called EcoVadis through APUC, to conduct part of our supply chain due diligence. EcoVadis have a well-developed methodology paired with a global team of expert analysts, which provides them with the ability to conduct individual sustainability performance assessments across all the relevant areas of our supplier/ supply chain community. Suppliers are selected to be invited on a risk-based approach per category.

EcoVadis assess suppliers across 21 indicators and four themes, environment, labour and human rights, ethics and sustainable procurement, which allows for an in-depth supply chain due diligence. Actions for suppliers are created based on the outcome of the assessment. A scorecard is produced for the supplier with areas of good practice and areas to improve. APUC and member institutions have visibility of the scorecard and can request corrective actions in areas for improvement, which suppliers must respond to and are documented within the platform. Further information can be accessed through the buyer success hub.

The College is a member of Electronics Watch, an independent monitoring organisation working to achieve respect for labour rights in the global electronics industry through socially responsible public purchasing in Europe.

The College uses the Scottish Government’s Sustainable procurement tools and guidance where appropriate at strategy stage of our procurements.

Every regulated procurement process conducted by the College requires tenderers to disclose whether the bidder or any member of their organisation with decision-making powers has been convicted in the last five years of any offence under Part 1 of the Human Trafficking and Exploitation (Scotland) Act 2015, or under any provision referred to in the Schedule to that Act. Tenderers that confirm such a conviction will be excluded from the process unless they can successfully demonstrate that they have self-cleansed.

The College includes a clause within its General Terms and Conditions in relation to Modern Slavery. This outlines the obligations of the supplier in contracting with the College. It extends to due diligence procedures being in place for sub-contractors to that supplier. It references the requirement for suppliers to comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes (including the Modern Slavery Act 2015). The College reserves the right to terminate and seek recompense for any contract where the supplier is found to be in breach of the anti-slavery policy. Police Scotland documents for Serious and Organised Crime (SOC) and Human Trafficking are embedded into our Invitation to Tender documents, where relevant and appropriate.

Training and Awareness

The College’s Procurement function continues to commit to undertaking all relevant training and awareness sessions, including the Sustainable Procurement training by APUC.

The College Procurement staff participate in the regular Electronics Watch webinars and workshops. APUC also offers an eLearning module on ‘Modern Slavery and Human Trafficking’ which Procurement Staff have attended.

In addition, the Scottish Government has the following training available via their website:

Scottish Government human trafficking training

and the home Office - includes videos to demonstrate examples of what to look out for in identifying Human Trafficking:

Home Office modern slavery training

Our Plans for the Future

Procurement staff will continue to participate in training and awareness sessions on sustainable procurement which includes Modern Slavery in the supply chain.

The Procurement Staff at the College shall continue to utilise the Sustainable Procurement Tools offered by APUC which includes a draft tender document, which includes full sustainable procurement references and a Modern Slavery Act compliance question, template strategy slides, the Sustain Supply Chain Code of Conduct, Prioritisation tool (based on the DEFRA Marrakech tool and the Scottish Government’s own updated tools), SCM (Supply Chain Management portal), and a variety of eLearning (including on Human Trafficking and preparing a Modern Slavery Statement).

The College shall continue to require contractors to complete Section 1 of the SCM portal and where appropriate invite contractors to participate in a deep dive assessment via Ecovadis to conduct supply chain due diligence.

APUC will re-assess all its framework agreements and contractors (including all new framework agreements let since last assessment) in order to re-prioritise those which are included in their due diligence tools, i.e. EcoVadis and SCM Section 1. APUC will engage with and promote partners such as Electronics Watch and attend relevant conferences to share good practice and discuss pertinent issues around modern slavery.

This statement has been approved by the Glasgow Clyde College Board of Management who will review and update it annually.

Jon Vincent
Principal and Chief Executive