Modern Slavery Statement

At Queen Margaret University we are committed to protecting and respecting human rights and have a zero tolerance approach to slavery and human trafficking in all its forms. This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and sets out the steps the University has taken during the financial year ended 31 July 2022 to ensure that slavery and human trafficking are not taking place in our supply chains nor in any part of our business. This statement will be reviewed annually.

The University’s Structure and Activities

Queen Margaret University, Edinburgh is registered under the UK Companies Acts as a company limited by guarantee. In accordance with the Companies Acts and the University’s Statutory Instrument, the University Court is responsible for the strategic development of the University, and for ensuring that the affairs of the University are administered and managed appropriately.

The University is organised into two Schools, the School of Arts, Social Sciences and Management and the School of Health Sciences. Professional services are provided through the Operations & Finance Group and the University Secretary’s Group.

The University educates students from all over the world and has partnership arrangements with organisations in Greece, Egypt, India, and Nepal. It seeks to attract and retain good staff by valuing them through transparent promotion opportunities, appropriate staff development, inclusivity and equality, and through instilling in our staff a strong sense of social responsibility.

Our Commitment

We recognise that modern slavery is a significant global human rights issue and includes human trafficking, forced and bonded labour, child labour, domestic servitude, and sex trafficking. We are committed to protecting and respecting human rights and have a zero tolerance approach to slavery and human trafficking in all its forms. We will act ethically and with integrity in all our relationships, and use all reasonable endeavours to take action directly and to influence others to ensure slavery and human trafficking is not taking place, wherever we can do so.

Our Human Resources policies set out our commitment to workplace rights at the University. Our Dignity at Work policy promotes an enabling and inclusive environment in which all members of the University community are treated with dignity and respect, and bullying, harassment and discrimination are known to be unacceptable. We are committed to fair, progressive and ethical working practices and have signed the Scottish Business Pledge. We have a Public Interest Disclosure (“Whistleblowing”) policy which enables staff to report improper conduct or unethical behaviour, and we have endorsed the Universities Scotland statement on the use of confidentiality clauses in Scottish higher education.

We have a number of policies which govern our relationships with business. We have a published University Procurement Strategy which displays our principles and practices in the acquisitions of goods, services and works, and outlines how we will take steps to ensure an ethical procurement approach. Our Ethical Investment Policy summarises the approach of the University in relation to investments.

Our Academic Collaboration policy governs our relationship with partners in the UK and Overseas, and we publish an annual statement on our Compliance with the Concordat for Research Integrity

Modern Slavery Risks in our Supply Chains and Other Areas

Queen Margaret University is a member of the Advanced Procurement for Universities (APUC Ltd), the procurement centre for expertise for Scotland’s universities and colleges. 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 function, which is provided as part of an APUC shared service. In relation to vetted suppliers, we use collaborative framework agreements put in place by APUC or other sectoral and national procurement consortia.

We buy a wide range of goods and services, including construction services and supplies, furniture and stationery, electronics (computers, audio visual, etc.), food and catering supplies, travel services, laboratory supplies (equipment, chemicals, pharmaceuticals etc.), books and printing, and waste and recycling services, and do so in accordance with public procurement law.

While the risk of modern slavery in our direct activities is likely to be low, we recognise that there are risks through the goods and services that we procure linked to supply chains around the world.

In addition, given the global reach of our University, we recognise that there are potential risks of modern slavery occurring related to our activities around the world, especially when located in high risk countries.

We work with others, such as universities, procurement bodies such as APUC, civil society organisations, and government agencies, to inform and mitigate risks.

Steps We Have Taken and Processes in Place to Identify and Mitigate Modern Slavery Risks:

Preventing modern slavery on our own premises. We are rigorous in checking that our staff have the right to work in the UK. Where it is necessary to hire agency workers or contractors, we utilise specified, reliable agencies who have met the University's rigorous procurement procedures regarding their business and employment policies and practices.

The University pays its staff the Real Living Wage and is accredited by the Living Wage Foundation. The University evaluates potential suppliers who will be working with the University, on and off the campus, on their approach to Fair work Practices, including the Real Living Wage.

Preventing modern slavery in our partner institutions. 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.

Educating and raising awareness among staff. The University promotes to all staff via its training and development calendar a number of self-guided training which cover modern slavery and human trafficking. These courses have been designed for the sector by BUFDG and HEPA and include A Guide to Modern Slavery, Intro to Sustainable Procurement, Advanced Sustainable Procurement and Protecting Human Rights in the Supply Chain.

Use of collaborative procurement and supply chain tools. The University includes the APUC and Higher Education Procurement Academy (HEPA) endorsed Sustain supply chain code of conduct in its regulated tenders. The University asks bidders to sign up to the terms of the code of conduct regarding social, ethical and environmental standards. The University also makes use of the Scottish Government’s sustainable procurement tools – flexible framework assessment tool, prioritisation tool and sustainability test – within its tender planning as appropriate and relevant.

Excluding any suppliers which have been convicted of offences of child labour or other forms of trafficking in human beings. Every regulated procurement process conducted by APUC on our behalf requires potential suppliers to disclose whether the bidder has been the subject of a conviction by final judgment within the last five years of any offence under Part 1 of the Human Trafficking and Exploitation (Scotland) Act 2015 or under any provision referred to in the Schedule to that Act. Any bidders with such a conviction will automatically be excluded from the bidding process, unless they can sufficiently demonstrate reliability of changes to their practices.

The University is a member of Electronics Watch, an organisation that works to ensure good working conditions in factories producing ICT goods bought by public sector members across Europe. Electronics Watch works with civil society organisations in the countries where our suppliers’ factories are located to monitor working conditions.

Listening to and protecting whistle-blowers. The University adheres to The Public Interest Disclosure Act 1998 and implements its own “Whistleblowing” policy regarding concerns about corruption, fraud or other malpractices within the University.

Taking action if modern slavery cases are found. If on site, any alleged violation of human rights will be fully investigated and appropriate disciplinary action will be taken against any member of staff found to have acted unethically and in breach of the University's commitment to human rights. If in our supply chains, the University in certain cases will have the right to terminate contracts where serious violations are discovered. In most cases we seek to engage, improve, highlight and recognise our responsibility to support the identification, mitigation and eradication of modern slavery in our supply base.

Screening donations to ensure they do not come from unethical sources. All proposed donations are considered in accordance with the University’s Gift Acceptance Policy. All proposed gifts of £5,000 or more are subject to due diligence by the Development Office, including searching for any connection to modern slavery. The extent of due diligence and of oversight applied will increase in line with an assessment of the risk associated with the potential donor and potential size of the donation.

Sir Paul Grice
Principal & Vice-Chancellor

February 2023