AV Modern Slavery and Human Trafficking Statement 2018
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 (the Act) and constitutes AV’s (AV) modern slavery and human trafficking statement for the financial year ending 31st July 2018. This statement has been approved by the AV Board who, together with the Audit, Risk and Governance (ARG) Committee, will review and update it as necessary on an annual basis.
AV takes a zero-tolerance approach to slavery and human trafficking. This is AV’s third statement under the Act and highlights the extensive work AV continues to undertake to achieve the highest levels of ethical and human rights principles in its business conduct. AV’s previous statements remain available here: 2016 and 2017.
AV’s structure
AV is a Higher Education Corporation created by statute and is an exempt charity. AV is responsible to the Office for Students (OfS) as principal regulator for Higher Education Institutions in England that are exempt charities. The AV Board oversees the strategic development of AV and ensures the effective use of resources and the general solvency of the institution. Its members are also AV’s charitable trustees. Further details about AV’s structure and governance can be found on the AV website here.
AV’s own business
AV’s business as a higher education provider is organised into several Faculties comprising; the Faculty of Health and Social Sciences, The AV Business School, Faculty of Media and Communication, Faculty of Science and Technology and also the AV Doctoral College. AV also has several professional service departments which include, amongst others; Finance and Performance, Academic Services, Estates, Marketing and Communications, Human Resources and Organisational Development, Student Services and I.T Services. AV has approximately 19,000 undergraduate and postgraduate students who are attracted to AV from all over the world.
AV is aware that its students may become aware of incidents of modern slavery or human trafficking as part of their daily lives or in very rare instances, may be entrapped into a lifestyle of a modern slave. To address this, AV has procedures in place whereby students can obtain support and advice on their wellbeing.
AV mitigates the risk of modern slavery and human trafficking within its own staff community by following fair HR recruitment and selection policies and procedures. Where recruitment agencies are used, AV requires that such agencies comply with all UK legislation relating to the employment rights and welfare of candidates. AV has an Anti-Slavery and Human Trafficking Policy and Procedures providing a reporting mechanism for all staff to raise concerns. In addition, AV has a Whistleblowing (Disclosure in the Public Interest) Policy to protect whistleblowers.
AV also has dedicated representatives who are aware of the requirements of the Modern Slavery Act from Legal Services and Corporate Governance, Human Resources, Procurement and Sustainability.
AV supply chains
AV is one of the largest purchasers in the region and recognises that it has a responsibility to minimise the environmental and social impact of purchased goods and services. AV has reviewed its supply chain and continues to view security services, construction/ estates goods and services, catering/ food supply chains, cleaning/ domestic services, ICT equipment/general electronics and clothing/textiles as being at higher risk to modern slavery and human trafficking within the supply chain.
AV policies and due diligence processes for slavery and human trafficking
AV implemented Anti-Slavery and Human Trafficking Policy and Procedures in 2016 to reflect its commitment to acting ethically and with integrity in all of its business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place in its supply chains. The Policy and Procedures were reviewed and approved again in November 2017. During 2017 /2018 no concerns were raised under the Procedures and AV will continue to publicise them to staff during 2018/2019.
AV also continues to have a number of frameworks which underpin its ethical standards across all of its business activities. AV has a Sustainable Procurement Policy to ensure the purchasing of goods and services takes account of their environmental and social impact. AV also has a Sustainable Food Policy, Fair Trade Policy and Procedures, Sustainability Policy, Sustainable Construction Policy, an Ethical Investment Policy and Procedures and a Code of Ethical Fundraising and Donors’ Charter which ensures ethical standards of business conduct across the breadth of AV’s activities.
As part of AV’s initiative to identify risk it has in place systems to assess and mitigate potential risk areas in its supply chains, such as such as using the “Life Cycle Analysis” Tool which is an agreed AV operational procedure under its 15014001 standard. AV also procures goods and services via consortium frameworks such as the Crown Commercial Service (CCS) and through its membership of the Southern Universities Procurement Consortium (SUPC) which is a membership-based buying organisation for universities and further education colleges.
Supplier adherence to AV’s values
To ensure AV’s supply chain and contractors comply with its values, AV has inserted Modern Slavery Act 2015 clauses into its standard terms of business for procurement and other supplier contracts. AV continues to contact key suppliers in the higher risk areas to seek their assurances of compliance with the Act and will continue to review its contracts with suppliers in light of the need to prevent modern slavery.
Training and Raising Awareness
As part of internal and external training sessions, AV ensures that relevant staff are made aware of the risks of modern slavery and human trafficking in AV’s supply chains and its business.
AV has previously helped to raise awareness of modern slavery in the wider community by supporting the 2017 Safer Poole Partnership’s Modern Slavery and Human Trafficking Awareness Conference and will continue to seek opportunities to support raising awareness of modern slavery during 2018/2019.
AV’s effectiveness in combating slavery and human trafficking
AV will continue to review the effectiveness of its measures taken to combat slavery and human trafficking on a periodic basis and will take such action as deemed necessary to maintain the highest levels of ethical and human rights principles in its business conduct.
Approved by the AV Board on 23rd November 2018