Modern Slavery Policy

This website conforms to the Bath Spa University Anti-Slavery Policy as laid out below.

Dated 20 November 2019

Bath Spa University is proud of its vision to be a leading university in creativity, culture and enterprise. Underpinning this vision is a principle to act ethically; the University is therefore committed to establishing practices to combat slavery and human trafficking.

The University is a Fairtrade University. Increasing the range of products bearing the Fairtrade Mark that are sold by the University ensures that the relevant parts of its supply chain are more likely to meet Fairtrade standards that protect workers’ rights and guarantee payment of a minimum price.

Bath Spa University is a higher education corporation established pursuant to the Education Reform Act 1988. It is also an exempt charity regulated by the Office for Students. The University’s principle place of business is at Newton Park, Newton St Loe, Bath BA2 9BN. The University has approximately 900 employees, the majority of which are based in the United Kingdom.

The University has two subsidiary companies, Bath Spa U Limited and Bath Spa Venues Limited. The annual turnover of the consolidated accounts of the University is in the region of £83,000,000.

The University comprises of eight academic schools: Bath Business School, Bath School of Art, School of Creative Industries, Bath School of Design, School of Education, School of Humanities, Bath School of Music and Performing Arts and the School of Science.

Several professional service departments exist to provide services to the students, the academic units, departments and fields. These include Human Resources, Academic Planning, Student Experience, Finance and Infrastructure, External, the University Secretary’s Office and others.

Within Finance, the procurement function supports departments in ensuring the University obtains value for money in all the goods and services it purchases, in-line with the University’s Financial Regulations and the Public Contracts Regulations 2015.

We have a zero tolerance to slavery and human trafficking. The University maintains policies relating to procurement, sustainability, equality, wellbeing and diversity which together form a robust institutional effort to combat slavery and human trafficking. Where relevant, our policies extend to our suppliers in expectations of adherence to external regulations and University principles.

The University’s procurement policies are concerned with adherence to the conditions outlined elsewhere in this statement and in ensuring due diligence, and include a sustainable procurement policy.

The University is committed to conducting its business with honesty and integrity, and it expects all staff to maintain high standards. Staff are encouraged to raise concerns of a public interest or make a public interest disclosure as part of the Whistleblowing Policy which is designed to allow concerns of a public interest arising in relation to the University to be raised, investigated and where appropriate, acted upon.

To ensure all those in our supply chain and contractors comply with our policies, we have in place a supply chain compliance programme.

Wherever possible our supply chain is made up of suppliers who are registered under framework agreements such as Southern Universities Purchasing Consortium, Crescent Purchasing Consortium, Crown Commercial Services and Health Trust Europe. Consultancies and construction work are also lodged under framework agreements to ensure compliancy with legislation.

Supply chain management from the consortia is routine throughout the contractual term and it is common for staff to manage contracts throughout the term to ensure value for money/compliancy.

On the occasions where a framework agreement cannot be used the University carries out due diligence on all new suppliers prior to placing a purchase order, as standard, this includes modern slavery questions. Further engagement with the suppliers is subject to review dependent on this confirmation step and the University’s standard contractual clauses explicitly require adherence by all suppliers to the Modern Slavery Act 2015.

The University works to identify and assess potential risk areas within its supply chains, monitor and mitigate any identified risk and to protect whistle-blowers raising concerns.

To ensure all those in the University and its supply chain and its contractors comply with our policies and procedures the University has put in place a supply chain compliance programme. This consists of procurement procedures, contract reviews and renewal of due diligence on contract renewal.

The University is committed to sustainable procurement and plans to implement ISO 20400 by 2025; a key part of this is the undertaking of a review of the University’s current procurement framework.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in University business and its supply chains, the University provides training to all appropriate staff.

The process all University staff must follow, in the engagement of a new supplier and inclusion of querying the suppliers’ efforts and steps taken to ensure compliance with the Act, acts as an engagement tool to ensure that staff access the resources made available in the provision of compliance.

The publication of this statement and the University’s approach to ensuring compliance with the Act is shared with staff via news and updates in line with the publication of the University’s financial statements.

The University Secretary’s Office will continue to provide advice and support, and work closely with colleagues across the University including Procurement, Finance and Estates functions to monitor higher risk areas within the University’s supply chain.

The University also plans to take steps to improve its contract management procedures, to ensure effective oversight of due diligence and timely contract monitoring.

The University’s Risk Management Framework has been updated which includes provision for a robust assessment of compliance risk, including the Modern Slavery Act 2015.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the University’s slavery and human trafficking statement for the financial year ending 31 July 2019. It was approved by the Board of Governors of Bath Spa University on 20 November 2019.