Modern Slavery and Human Trafficking Statement
- This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the college’s slavery and human trafficking statement for the financial year ending 31st July 2018.
- Dudley College is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its services. This statement sets out the preventative steps that the college is taking (and intends to take) to avoid the risk of modern slavery occurring within college services.
- Dudley College is a long established further education college situated in the Black Country metropolitan borough of Dudley.
- The college’s main business is to deliver education and training to students aged 14 and upwards and covers a range of technical and academic programmes.
- The college employs approximately 750 staff and has an annual turnover of £42.
Due diligence processes
- As part of our initiative to identify and mitigate the risks of modern slavery occurring in any part of college services, the college will adopt due diligence processes that are proportionate to any risk areas identified (dependent on the severity of the risk and other relevant factors). These processes will be subject to on-going assessment and review.
- The college has in place systems to:
- Identify and assess the potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chain.
- Protect whistle blowers.
- The college identifies the following as the principal areas of potential risk: - Supply chains for goods and services, particularly IT equipment and uniforms; outsourced cleaning and security services. - Recruitment agencies for temporary staff.
- In its supply chains, the college has identified the following business areas as carrying material risks of modern slavery occurring:
- IT equipment.
- Clothing and uniforms.
- Outsourced cleaning.
- Capital construction projects.
- Outsourced security services.
- When tendering any types of goods or services, the college requires any potential third party suppliers to evidence that they operate a high level of corporate social responsibility and comply with the Modern Slavery Act 2015 during any tendering and selection processes, including through contracting with suppliers from approved procurement frameworks.
- When procuring any types of goods or services identified as carrying material risks of modern slavery occurring (4.1) the college requires any supplier to evidence that they operate a high level of corporate social responsibility and comply with the Modern Slavery Act 2015.
- Any supplier or potential supplier, identified in 4.2 or 4.3, wishing to supply to or partner with the college that does not comply with the Modern Slavery Act 2015, or the college’s own policies and procedures, will be removed from the college’s list of suppliers and will not be considered for future supply to the college unless they can demonstrate that these compliance requirements are met.
- In terms of future steps, the college will review the viability of introducing other due diligence processes for monitoring and managing identified risks, including risks associated with particular countries and products.
- To ensure an appropriate level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff responsible for recruitment, procurement and contract management.
- Temporary staff and staff recruited indirectly by the college are recruited through agreed, reputable recruitment agencies. To mitigate the risk of any potential occurrences of modern slavery, the college conducts checks on such agencies before they are approved.
- Through its recruitment processes, the college ensures that all approved recruitment agencies conduct all relevant pre-recruitment checks and provide evidence that all such checks have been conducted.
- The college already implements the following policies, which embed good practice and providing remedies for individuals concerned about any potential instances of modern slavery in any part of college business. The college operates the following policies and procedures:
- Grievance and Whistleblowing procedures – these procedures allow employees, students and others to raise concerns, which would include circumstances giving rise to a risk of modern slavery, without fear of retaliation.
- Professional Code of Conduct – this code sets out the actions and behaviour expected of them whilst employed by the college. The college strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain.
- Anti-bribery and Corruption policy – the college is committed to the highest standards of ethical conduct and integrity in its business activities. The college will not tolerate any form of bribery or corruption by its employees or any person or body acting on its behalf.
- Value for Money policy and Financial Regulations – these documents reflect the college’s commitment to acting ethically and with integrity in its business relationships, as well as implementing and enforcing effective and proportionate safeguards and controls.
- Recruitment and Selection procedure – this procedure ensures that the college follows transparent recruitment processes, including measures to prevent illegal working and compliance with other relevant statutory requirements.
- Where the college has identified risks of modern slavery occurring in any part of its services, it will aim to introduce performance indicators (KPIs) to measure progress against reducing such risks. The college will consider setting and reviewing KPIs in the following contexts:
- Use of grievance and whistleblowing procedures by staff to raise concerns about instances of modern slavery.
- Assessment of third party suppliers of relevant goods and services and their supply chains.
- This statement will be made available to all staff members, stakeholders and the general public by publication on our website. We will also seek to raise awareness of the risks of modern slavery amongst staff by other measures.
- Having assessed the training needs for staff operating in different parts of the college, the college will look at devising and implementing training and awareness-raising methods attuned to relevant staffing groups. Training courses may be devised in co-operation with external, specialist training providers.
For any general concerns regarding anti-slavery, there is a wealth of information and contact points through the following link:
This statement has been approved by the college’s senior leadership group and governing body and will be reviewed every two years.
Issue No: 001
Document Change Note Ref: 1968
Review Date: 13.03.2020
EIA Date: 14.03.2018