Modern Slavery statement

Introduction

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and sets out the steps that Edinburgh Napier University has taken during the financial year ending 31 July 2025 to ensure that slavery and human trafficking are not taking place in our supply chains, or in any part of our business. This statement will be reviewed annually.

Edinburgh Napier University structure, business and supply chain

Our purpose is to deliver high quality education and research and to add value to the social, cultural and economic capital of the communities we serve. We work at the leading edge of our academic disciplines in research, pedagogy and professional practice, developing highly valued graduates and delivering research outcomes that together transform communities.

For procurement, Edinburgh Napier University is part of the Institutional Procurement (shared) Services provided by Advanced Procurement for Universities and Colleges (APUC) Ltd, the procurement Centre of Expertise for Scotland’s Universities and Colleges. The University benefits from its close links with APUC in a number of areas within sustainable and responsible Procurement.

Key categories

We contract with our suppliers for works, goods and services in three key categories aligned to APUC’s Strategic Sourcing category structure:

• Estates & Facilities;
• Information Services;
• Corporate and Labs.

Edinburgh Napier University employs a central procurement team led by the Head of Strategic Procurement. The team acts as dedicated Procurement Business Partners for all Schools and Departments in the University. The embedded procurement team is employed directly by APUC, as part of an extensive shared services agreement. Through this approach the University benefits from the flow of sustainable procurement best practice to internal procurement processes.  A sizeable proportion of our procurement is with suppliers who are pre-approved either by a purchasing consortium or through public tenders managed by our procurement team. In relation to vetted suppliers, we use collaborative framework agreements wherever practicable, awarded by APUC or other sectoral and national procurement consortia (Crown Commercial Services; Scottish Procurement, etc.).

Organisational policies

The University has a zero-tolerance policy in relation to modern slavery and human trafficking in any part of our business and in our supply chain. We require high professional standards of behaviour throughout the institution and have implemented a wide range of policies, guides and training to ensure these standards are met. We are committed to acquiring goods and services for our use without causing harm to others and are committed to acting ethically and with integrity in all our business relationships.

The University has adopted tools and practices from APUC to address modern slavery and human trafficking, including but not limited to prohibition of forced labour, prohibition of child labour and non-discrimination. For all open tenders with a contract value above the Scottish Government threshold, the University uses the APUC template tender document (which includes full sustainable procurement references and a Modern Slavery Act compliance question).  As part of the tendering process, the University also adopts the amended Sustain Supply Chain Code of Conduct (whose principles cover Social Compliance including suitable and fair working conditions, Ethical and Environmental Compliance as well as Economic Development).

By signing and submitting to the Code of Conduct, bidders acknowledge their compliance with these principles. The code also requires suppliers to the University to ensure that their own suppliers adhere to the same principles, to enforce and promote these practices throughout their own supply chain.  

In addition, for all open tenders with a contract value above the EU threshold, we require bidders to complete the Single Procurement Document (Scotland).  In completing this, bidders declare that they have not committed any offence under Part 1 of the Human Trafficking and Exploitation (Scotland) Act 2015 or under any provision referred to in the Schedule in that Act.

Due diligence and risk asessment

Edinburgh Napier University conducts a variety of due diligence checks across the organisation including with external partners it works with. This includes for instance pre-agreement checks and questionnaires in relation to overseas student recruitment agents, and contracts which set out clearly the University’s expectations on the services (and limits to them) delivered to students.

The following category areas with potential high-risk for modern slavery in the supply chain have been identified. The University ensures suppliers’ own modern slavery statements meet the university standard. Suppliers must take relevant and proportionate due diligence to mitigate any modern slavery risks in their supply chain.

• Catering
• IT
• Travel
• Utilities
• Cleaning

Edinburgh Napier University uses many national and sectoral framework agreements to let contracts, it is also relevant that APUC have undertaken prioritisation on framework agreements either led or promoted by APUC, to understand the key sustainable procurement risks and opportunities for each agreement, which includes possible labour concerns. This helps APUC to assess which agreements and suppliers should be audited on compliance with its Sustain Supply Chain Code of Conduct.

To assess suppliers’ compliance with the Sustain Supply Chain Code of Conduct, the procurement team use the Supply Chain Management portal (SCM) - the APUC web-based sustainable procurement tool which links to the HUNTER contracts database, containing contracts/agreements used by institutions throughout the HE and FE sectors. ENU Suppliers have been invited to complete a set of questions which allows the University to verify that its contractors have published their own Modern Slavery statements. The tool assesses suppliers over a variety of achievement/compliance levels in social, ethical, economic and environmental areas, including recruitment processes and employment terms for workforces. The assessments are conducted by SA8000 trained staff within APUC’s Responsible Procurement team. The tool enables procurement managers to view the status of their suppliers, and for sub-tier suppliers to be linked/assessed. In order to further increase the transparency around suppliers’ responsible business performance, APUC has also chosen EcoVadis, a global Corporate Social Responsibility rating company based on international standards, to conduct individual sustainability performance assessments across all relevant areas of our supplier / supply chain community. Edinburgh Napier University was one of the early adopters to use this service in the sector. Suppliers are being assessed and receive a sustainability scorecard from EcoVadis with detailed insights into their strengths along with opportunities for improvement. The supplier assessments are reviewed annually.

By virtue of its membership of APUC, Edinburgh Napier University is a Consortium Affiliate 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 Head of Strategic Procurement at ENU sits on the Board of Trustees of Electronics Watch. We complete Affiliate Product Forms annually for ICT and related equipment, and work with our suppliers to respond to any areas of concern flagged by Electronics Watch’s project co-ordinators.

The principal areas that have been highlighted by the sector as being potentially high risk in terms of Modern Slavery are those with a greater percentage of agency workers or outsourced services such as Construction, Hospitality and Cleaning Services. To address this, the University has taken additional steps within our local agreements which may fall into a higher risk category.

With regards to staffing departments where there is an elevated risk of modern slavery and human trafficking, Edinburgh Napier University employs directly nearly all catering, cleaning and security staff on our main campuses with the exception of cleaning in Student Accommodation. These areas are managed by Property and Facilities Services via dedicated team leaders.

Living wage and working hours

The University is proud to be an UK Accredited Living Wage Employer. The University met the UK Living Wage pay thresholds for all staff and also includes all contracted workers/suppliers that regularly work on our premises (more than two hours in any given day in a week for eight consecutive weeks) within the same pay thresholds. The University offers flexible working when possible, and has ensured that employees earn a fair wage that meets the costs of living, not just the Government minimum. The University also adheres to all applicable working-hours regulations.

Training

In addition to the HEPA (Higher Education Procurement Association) Modern Slavery training, members of the Procurement team continue to take part in all relevant training and awareness raising sessions organised by the sector.

The Procurement team continues to have representation on the APUC Sustainable Procurement Leaders Group (SPLG) and the HEPA Responsible Procurement Group. The SPLG brings together representatives from APUC members as well as all Category Directors to consider all key issues related to sustainable procurement and looks at ways to increase/ improve sector awareness. The HEPA Responsible Procurement Group is a national (UK) working group which seeks to address the issues surrounding Responsible Procurement. Topics covered include, but will not be limited to Modern Slavery, Workers Rights, Sustainable and Ethical Procurement in Higher Education with an aim to increase awareness, improve working practice and encourage collaboration between Universities and also their suppliers. 

Professor Sue Rigby
Principal & Vice Chancellor