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Slavery and Human Trafficking Statement for the Financial Year Ending 31 July 2016
Introduction from the Chair
This statement is made pursuant to Section 54(1), Part 6 of the Modern Slavery Act 2015 and constitutes UCAS’ slavery and human trafficking statement for the financial year ending 31 July 2016. It sets out the steps UCAS and UCAS Media Limited have taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
Slavery and human trafficking remains a hidden blight on our global society. We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Staff are expected to report concerns and management are expected to act upon them.
UCAS is a charity that provides applications and admissions services, across a range of subject areas and modes of study, for UK higher education providers. UCAS is the parent company of a wholly owned subsidiary, UCAS Media Limited, which is a commercial enterprise that offers marketing solutions to clients wishing to reach students and their influencers. The group has its head office in Cheltenham, UK with a satellite office in London, UK. The group has an annual turnover in excess of £42 million.
Our business is organised into seven business units:
- Operations – delivers planning, oversight, and delivery of the end-to-end annual admissions delivery cycle across all UCAS schemes
- Analysis and Research – provides high quality research and analysis services to underpin the UCAS business and meet the needs of our customers
- External Relations – provides intelligence and insight to enhance UCAS’ reputation and to drive and inform the strategic development of products and services
- Finance and Corporate Services – encompasses financial planning and accounting, facilities and building management, procurement, corporate governance and performance, organisational development, and legal and compliance
- Information Technology (IT) – is responsible for the IT backbone which supports the UCAS business model
- Customer Experience and Marketing – communicates with a whole range of audiences, such as providers, students, and commercial clients
- UCAS Media Limited – offers marketing and brand insight services and data products and tools to public and private customers. It generates revenue which is then reinvested back into the charity to further its charitable objects.
Our Supply Chains
Our supply chain network is largely service driven to benefit our learners and higher education providers. The services provided by our suppliers include managed IT services, overflow outsourced call centre activity, venue hire, agency labour and contractors as well as support supply chains incorporating IT equipment, facilities management, cleaning, catering, security, office furniture and workwear.
Our Policies on Slavery and Human Trafficking
We are committed to ensuring that modern slavery and human trafficking do not infect our supply chains or any part of our business. Our Procurement Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective and proportionate safeguards and controls.
Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk we have established the Commercial Working Group responsible for developing systems to:
- Identify and assess potential risk areas in our business affairs
- Mitigate the risk of modern slavery and human trafficking
- Monitor potential risk areas
- Protect whistleblowers.
To ensure a high level of understanding of the risks of modern slavery and human trafficking within our business, it is expected that the members of the Commercial Working Group will be required to attend appropriate training and guidance.
Supplier Adherence to Our Values
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values, our terms and conditions for the supply of goods and services require suppliers to:
- comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including without limitation the Modern Slavery Act 2015
- have and maintain throughout the term of this agreement its own Anti-slavery Policy and procedures to ensure its compliance
- not engage in any activity, practice or conduct that would constitute an offence under sections 1, 2 or 4, of the Modern Slavery Act 2015 if such activity, practice or conduct were carried out in the UK, and
- ensure that each of their subcontractors and suppliers shall comply with their Anti¬-slavery Policy and with all applicable anti¬slavery and human trafficking laws, statutes, regulations and codes from time to time in force including, without limitation, the Modern Slavery Act 2015.
Our Procurement team has raised awareness of these changes through email distributions asking suppliers to review our terms and conditions. Where the business has outsourced services, there are dedicated staff responsible for the effective management and control of the outsourcing relationships. This activity is further supported by the Commercial Working Group, which reviews and evaluates risks within the supply chain.
This statement was approved by the Board of Directors of UCAS on 22 September 2016.
Signed for and on behalf of the Board of Directors of UCAS by
Professor Sir Steve Smith
Date: 22 September 2016