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 31st July 2020 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 & 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.
Edinburgh Napier is an international university, home to over 20,000 students from 140 countries. We are also a leader in transnational education and the largest UK provider of higher education in Hong Kong.
Edinburgh Napier University is a member of the Advanced Procurement for Universities and Colleges (APUC) Ltd, the procurement centre for expertise for Scotland’s universities and colleges. The University benefits from its close links with APUC in a number of areas within sustainable procurement.
We contract with our suppliers for works, good and services in each of the six categories aligned to APUC’s category structure.
- Information Services;
- Human Resources;
- Professional Services;
Edinburgh Napier University employs a central procurement team of three FTE and two 0.5 FTE which includes the following roles: Head of Procurement, two advanced Procurement Managers, one Operational Procurement Manager and one Procurement Administrator. Each team member acts as a Procurement Client Partner for a group of Schools and departments. The embedded procurement team is employed directly by APUC, as part of an extended shared service agreement. Through this approach the University benefits from the flow of sustainable procurement best practice to internal procurement processes.
A significant 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 put in place by APUC or other sectoral and national procurement consortia.
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. 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 European 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, risk assessment and response
Edinburgh Napier University carries out a variety of due diligence checks across the organisation such as the requirements for candidate recruitment agents for the Global Online programme to complete a background questionnaire. The University is actively engaged with partner institutions overseas and undertakes rigorous and comprehensive due diligence such as for potential partner institutions to be assessed using a financial risk matrix and a reputational due diligence report.
As 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.
Further to this, Edinburgh Napier University Procurement team have undertaken their own assessment using the Prioritisation tool to assess contracted suppliers where spend is classed as influenceable. The Prioritisation Tool is a 13 point risk assessment where suppliers are entered into the matrix and risk scored against a number of categories such as financial risk, supply chain vulnerability, sustainability, modern slavery and living wage checks.
To assess suppliers’ compliance with the Sustain Supply Chain Code of Conduct, the procurement team has access to Sustain - the APUC web-based assessment tool which links to the contracts database containing contracts/agreements used by the whole sector. The website assesses suppliers at three achievement/compliance levels in social, ethical, economic and environmental areas. The assessments are carried out by SA8000 trained staff within APUC’s Development and Sustainability team. The tool enables procurement managers to view the status of their suppliers, and for sub tier suppliers to be linked/assessed.
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 main 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 a high 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.
One of the areas that has been highlighted as subject to high risk due to unskilled labour is Cleaning Services. As part of the tendering process for the Student Accommodation Cleaning Services, a weighted Modern Slavery specific evaluation question was asked, and each bidder was scored on their response. Each bidder was also requested to provide detailed copies of their own Modern Slavery policies and demonstrate how this was managed throughout their organisation. The successful bidder scored well on this question and was also verified as Scottish Living Wage provider.
With regards to the Construction sector, the University initiated a collaborative tendering process for Minor Works where a framework will eventually be awarded in conjunction with another Edinburgh based University. As this sector has been highlighted as high risk, the University will put greater emphasis on the Modern Slavery policies of all potential bidders and ask for information on how these policies are integrated into their workplaces and supply chains.
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. More recently, a member of the team has undertaken Sustain verifier training in order to assess evidence provided by University suppliers through the Sustain process.
The Procurement team continues to have representation on both the APUC Sustainable Procurement Leaders Group and the HEPA Responsible Procurement Group and the Universities Scotland sub-committee Responsible Universities Group Scotland. The Sustainable Procurement Leaders Group brings together representatives from APUC members as well as all Heads of Category 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. The Universities Scotland sub-committee Responsible Universities Group Scotland includes representatives from key professional service departments within Scottish Universities as well as relevant stakeholders. The purpose of the sub-committee is to encourage Scottish universities to be an exemplar sector for sustainability and corporate responsibility. Detailed work includes encouraging and identifying key sector contributions to more circular consumption models and ethical supply chains for goods and services.
Professor Andrea Nolan CBE
Principal & Vice Chancellor