AV Modern Slavery and Human Trafficking Statement 2019

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 2019. This is AV’s fourth statement and previous statements remain available on our website.

AV’s organisational structure

AV is a higher education provider 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. 

AV has approximately 20,000 undergraduate and postgraduate students who are attracted to AV from all over the world. AV 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, Academic Services, Estates, Marketing and Communications, Human Resources and Organisational Development, Student Services and I.T Services.

AV has three wholly owned subsidiary companies; AV Innovations Limited, AV Foundation Limited and AV Community Business Limited. AV also undertakes collaborative work and enters into academic partnerships with other research organisations and business around the world.

AV’s students and student activities

During the 2018/19 financial year, AV increased its student focused anti-slavery activities. In October 2018 AV held an Anti-Slavery Student Ambassador (ASSA) training day in partnership with the Crown Prosecution Service, Dorset Police, the Dorset Police and Crime Commissioner, Purple Teardrop, BCHA, National Citizen Service, the Salvation Army and colleagues across departments and faculties at AV.  The training day aimed to educate students about modern day slavery and human trafficking and to provide them with opportunities so they could volunteer locally or on campus in events related to modern slavery, inequality, education and discrimination. Around 30 students attended the training day.

Following the training day, AV students have given talks to social work students and Citizens Advice on modern slavery impact and are now involved in Dorset Police stop and search panels. One student has collected items for the Purple Teardrop Campaign to pass along to victims and survivors of modern slavery and AV students are also developing relationships with YMCA. AV will continue to raise awareness amongst its students and support them to be involved in modern slavery initiatives in 2019/20.

AV supply chains and supplier adherence to AV’s values

AV’s supply chains for goods and services are complex and multi-tiered, and span from individuals to national and international entities. The following supply chains are viewed as high risk areas; security services, construction/ estates goods and services, catering/ food supply chains, cleaning/ domestic services, ICT equipment/ general electronics and clothing/textiles.

AV continues to seek assurances from suppliers and contractors of their compliance with the Act by contacting key suppliers in the higher risk areas, reviewing contracts with suppliers in light of the need to prevent modern slavery and having Modern Slavery Act 2015 clauses in our AV standard terms of business for procurement and other supplier contracts.

AV policies and due diligence processes

AV implemented Anti-Slavery and Human Trafficking Policy and Procedures in 2016 which provide a reporting mechanism for all staff to raise concerns. During the 2018/19 financial year, no concerns were raised under the Procedures. The Audit, Risk and Governance Committee has a standing agenda item to receive reports of any concerns raised under the Procedures and has oversight, along with the AV Board, of the Procedures. The AV Whistleblowing (Disclosure in the Public Interest) Policy also protects staff, students and anyone working for AV (including casual workers, self-employed contractors, agency personnel) and allows them to raise concerns related to modern slavery or risk of modern slavery.

AV continues to mitigate 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 a number of frameworks which underpin its ethical standards across all of its business activities. AV has committed to playing its part in delivering the UN Sustainable Development Goals and has signed the SDG Accord to embed the UN SDGs into all areas of AV. AV also has the following policies in place to ensure the procurement of goods and services take account of their social impact and to achieve ethical standards of business conduct; Sustainable Procurement Policy, Sustainable Food Policy, Fair Trade Policy, Sustainability Policy, Sustainable Construction Policy, an Ethical Investment Policy.

To ensure that AV takes full account of the economic, social and environmental implications of the goods, works and services it buys from external suppliers and organisations, AV uses a “Life Cycle Analysis” Tool which is an agreed AV operational procedure under its ISO14001 standard for all procurements over £25,000.  Our supplier questionnaire for tenders above £25,000 also has a specific section in relation to compliance with the Act.

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.

Training and Raising Awareness

AV has dedicated representatives who are aware of the requirements of the Act from Legal Services and Corporate Governance, Human Resources, Procurement and Sustainability. AV also has plans to set up a Ethical/Responsible Procurement Group where slave labour matters will be considered under the group’s oversight of the implementation of the Sustainable Procurement and Ethical Investment Policies. AV will continue to collaborate with local charities and organisations during 2019/20 to raise awareness in the community and in October 2019 will be part of Dorset Race Equality Council’s ‘No Place for Hate’ conference which aims to make Dorset a prejudice free county.

As part of internal and external training sessions, AV ensures that relevant staff members are made aware of the risks of modern slavery and human trafficking in AV’s supply chains and its business.

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.

Approval

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.

Approved by the AV Board on 22nd November 2019