Liverpool John Moores University Modern Slavery and Human Trafficking Statement 2021/22

Introduction

This statement has been published in accordance with section 54(1) of the Modern Slavery Act 2015. It sets out the steps taken by Liverpool John Moores University during the financial year ending 31 July 2022 to prevent Modern Slavery and Human Trafficking in its business and supply chains.

Liverpool John Moores University published its first Modern Slavery transparency statement in January 2017. Since then, we have taken positive steps towards increasing our understanding of the risks we face. We know that slavery, servitude, forced labour and human trafficking is a global issue, existing in every region in the world and in every type of economy.

As a university with a global approach and footprint, we are committed to improving our practices to play our part in eradicating slavery and human trafficking and significantly minimising the risk of slavery and human trafficking taking place in our supply chains or in any parts of our business.

Our Organisation, Structure and Supply Chain

Liverpool John Moores University is a UK Higher Education Institution, integral to the life of the city of Liverpool, with a global approach and a footprint forging international partnerships to facilitate world-leading research and collaboration to tackle some of the huge global issues facing the modern world.

The university has two campus areas, Mount Pleasant and the City campus comprising thirty-one buildings. We are structured around five academic faculties supported by a Professional Services infrastructure.

As of 31 July 2022, the university had three subsidiary companies, all based in the UK:

JMU Services Limited
LJMU Recruitment Agency Limited
The Liverpool Business School Limited

The university has a 50% interest in the company Sensor City Liverpool Limited, which is treated as a joint venture, a 25% interest in Sciontec Developments Limited, which is treated as an associate, and which owns 100% of Liverpool Science Park Limited.

In respect of Modern Slavery, we have two main risk areas:

People: our large population of staff and students. We accord the welfare of staff, students, and visitors the highest priority. The vast majority of LJMU students are from the UK but we have a growing international population from a large number of countries, particularly India.
Supply chains: we have a large and complex supply chain to support our academic activities and campus operations. We purchase a diverse range of goods and services and have more than 7,000 active suppliers listed on our Finance System. Regardless of what we buy we are committed to acquiring it in a responsible manner. Our approach is to “change the world one tender at a time, using each exercise as an opportunity to address inequalities” (Dr Olga Martin Ortega – Greenwich University)

Our Policies and Processes relating to Slavery and Human Trafficking

Our approach around the issue of modern slavery is consistent with our civic origins and our values. Our internal policies and processes support this.

We have had an Anti-Slavery and Human Trafficking Policy in place since 2017.
We have an Ethics Policy Framework, designed to organise the university's ethics related policies into categories and groups to assist staff in giving due consideration to ethical issues arising from the university's activities. This is an overarching framework providing guidance to support the university's vision, mission, and values. The Ethical Investment Policy, Procurement Strategy, and Financial Due Diligence Process are all set within that Framework.
We have a Safeguarding Policy which is intended to support the safeguarding of any child, young person or vulnerable person who is part of, or comes into contact with, the university community.
We operate a Whistleblowing Policy for our employees, students and others working in our supply chains, to encourage the reporting of any wrongdoing, which extends to human rights violations like Modern Slavery. All reports are fully investigated, and appropriate remedial actions taken where required.
We regularly review our procurement documentation and processes to ensure they reflect best practice. We have this year incorporated Social Value Criteria into our tendering exercises. All LJMU tender documents encompass Modern Slavery Statements which suppliers are required to sign up to.
We have established a Climate Change Panel, which has produced a Climate Change Action Plan which addresses inequalities in the Supply Chain.

Our Approach to Understanding and Managing Risk of Modern Slavery

As outlined above the two main risk areas for the university in terms of slavery and trafficking relate to people and supply chains.

In terms of people, we continue to integrate the consideration of modern slavery risks into our wider risk management framework.

We have formalised our internal governance of this risk at the highest level: Pro-Vice-Chancellors of each academic area and the Executive Leadership Team (ELT) lead of each of the business services divisions is responsible for ensuring that their respective areas comply with due diligence requirements set and overseen by the finance team in relation to the approval and use of suppliers and the approval of collaborative partners. Pro-Vice-Chancellors and ELT leads are required to certify compliance in their respective areas on an annual basis.
At the point of recruitment, we ensure that appropriate checks on prospective employees are completed in accordance with the law. We have a comprehensive Recruitment Policy and mandatory training programme for those involved in recruitment to ensure compliance.
The university has a subsidiary company LJMU Recruitment Agency Limited (LJMURA), a franchise of Unitemps, through which it offers temporary work to LJMU students and alumni. Providing work experience opportunities and supporting students’ financial sustainability whilst studying. LJMU utilises LJMURA for temporary staffing requirements.

In terms of the supplier risks:

We continue to work on understanding our supply chain. We procure goods and services from suppliers across the world and although we consider our day-to-day activities are low risk, we recognise that the global nature of our supply chains may increase the risk of Modern Slavery occurring, particularly in high-risk industries and high-risk countries. As part of our initiative to identify and mitigate risk in respect of our supply chain, we are continuing to implement and improve systems to identify and assess potential risk areas in our supply chains. As stated, we have in excess 7,000 suppliers listed on our Finance System. The majority of spend is with 500 suppliers, with whom we either contract directly or through a public procurement framework agreement. In both cases suppliers are subject to a full selection process (UK Government Cabinet Office – SQ used), which evaluates their capacity and capability to supply, and includes assessments of, amongst other things, their supply chain practices and adherence to modern slavery legislation.
As stated above, LJMU make use of a number of external framework contracts; high level contract management is undertaken by each letting authority. This includes monitoring company capability and capacity, as well as general reviews of their wider business practices to provide necessary assurance to contract users. We work closely The Northwest Universities Consortium (NWUPC) and The University Catering Organisation (TUCO).
To manage risks through their contract management processes both these consortia have incorporated physical supplier visits for UK based companies within their contract management practices. These include a visual inspection of the premises including looking for any signs of slavery, This provides assurance that working practices meet our expectations.
During 2021/22 we have continued to subscribe to the supplier sustainability toolkit NETpositive. The toolkit enables suppliers to sign up and develop their own sustainability action plan. The tool addresses Modern Slavery risks, encouraging suppliers to develop a code of conduct and publish a Modern Slavery Transparency Statement. The most recent benefit from this tool, is to monitor climate change action amongst our supply chain. Each supplier is encouraged to share with us details of the impacts arising from their business activities, including slavery and their supply chains. This provides an opportunity for them to tell us how they are addressing these issues.
Since September 2019, the university has been an affiliate member of Electronics Watch through NWUPC. Electronics Watch is an independent body which assists public sector organisations to ensure the rights of workers in the electronics industry are protected.
We are committed to ensuring that people are paid appropriately for the work that they carry out. In March 2016, we became the first University in Liverpool, and the largest employer in Liverpool, to be accredited as a Living Wage employer.

Staff Training and Promoting Awareness of Slavery and Human Trafficking

We remain committed to raising awareness of modern slavery amongst staff.

To ensure a high level of understanding of the risks of Modern Slavery and Human Trafficking in our supply chains the university requires all staff to undergo an e-learning module on Modern Slavery renewable every three years. The training aims to raise awareness of Modern Slavery and outlines the university’s obligations in addition to advising staff of the correct channels through which concerns can be raised. The number of new staff who completed this training in 2021/22 is 407.
The university has a second, more comprehensive, e-learning module which includes detailed case studies to inform staff of the different forms Modern Slavery can take. This has been targeted at Finance, Legal and Governance, International Relations and Research and Innovation Services staff.
At the point of recruitment, we ensure that appropriate checks on prospective employees are completed in accordance with the law. We have a comprehensive Recruitment Policy and mandatory training programme for those involved in recruitment to ensure compliance.
In 2021/22 we commenced the delivery of Finance Clinics, which were held throughout the year with LJMU Faculties. Within these clinics, we re-iterate LJMU Financial Regulations including regulations around the purchase of goods and services. We reinforce the importance of supplier selection and consideration of wider factors (beyond price) when engaging with a company.
Our Procurement Team are professionally qualified (MCIPs) or working towards attaining these qualifications.

Steps taken in Preventing Modern Slavery and Human Trafficking during 2021/22

We have continued to build on the work started in previous years to eliminate the risk of Modern Slavery and Human Trafficking from our business and supply chain. We appreciate that this risk is not static and that this will be a long and continuing journey, as we raise awareness both within the university and with our partners and stakeholders. The progress we have made is summarised below:

The continuation of the use of e-Learning modules to deliver mandatory training to staff on the Modern Slavery and Human Trafficking.
We continued to embed Modern Slavery controls and requirements in our standard contracting and partnership processes.
The initiation of delivery of Finance Clinics across the university as described above.
The review of our procurement “How To” guides for LJMU staff to ensure they have access to appropriate topic specific guidance on procurement.
The implementation of a Helpdesk to allow us to provide a more efficient and effective procurement support.
We reviewed our Anti-Slavery and Human Trafficking Policy and other related policies, including our Ethical Investment Policy.
We initiated the development of Business Intelligence reports to facilitate the reporting on and management of our supplier base.

Understanding Our Supplier Base

During 2021/22 we purchased or accrued approximately £92m of goods, services and works through various supply chain arrangements. We have engaged with 2,900 suppliers from 65 countries and territories

Our Plans for the Future

We commit to continue to better understand our supply chains in their entirety and work towards greater transparency and responsibility towards people working within them.

We will continue to implement and develop the following action plan to address the risks Modern Slavery and Human Trafficking represent in our business and supply chains:

We will continue to carry out supplier and partner risk assessments and embed our MSA due diligence into the supplier and partner set up process.
We will review and monitor supplier action plans through regular contract management and support initiatives to reduce the risk of Modern Slavery and Human Trafficking occurring.
We will continue to embed our Anti-Slavery and Human Trafficking Policy.
We will continue to provide training for all key staff on MSA compliance.
We will continue to review and update all relevant policies and controls to embed MSA awareness.
The LJMU Supplier code of conduct is currently included in all our Tender documentation. All suppliers must subscribe to this. The Code of Conduct will be placed on the LJMU external website and referenced in the new supplier form.
Finance Clinics will continue and content further developed.

We will continue the development of Business Intelligence reports to facilitate the reporting on and management of our supplier base.