Uniac - July 2022

8 more tiers that exist in the supply chain, and the greater the complexity of the chain, the greater the challenge that institutions face to ensure that modern slavery is not taking place. There was some evidence of risk assessments that also took into account geography at a country level. We also note that whilst all statements referred to supply chains, there was limited information regarding organisations’ own business operations, as well as a general lack of detail around the specific risks that exist in institutions’ supply chains and the steps taken to address higher risks, perhaps in order to avoid institutions’ disclosing too much detail about their activities, which may also draw comparison with others. Whilst mindful of confidentiality, we think institutions should consider increasing transparency in this area as part of their statements through including greater detail around their risk assessments in terms of how they were conducted, the criteria used and the actions that have been, or will be taken, in response, to address modern slavery risks in their business operations and supply chains. • its effectiveness in ensuring slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate. This was clearly the weakest area reported on across all of the statements reviewed, with all statements virtually silent in this regard. There was little by way of reference to the effectiveness of institutions’ activities in this area and none included any specific or relevant measurable goals or Key Performance Indicators (KPIs). As a minimum, we would expect linkage to existing KPIs that are relevant to modern slavery - for example, bespoke or integrated staff training in this area. As well as existing KPIs that may be relevant or contribute to modern slavery, institutions should also consider developing new KPIs and associated targets to measure performance and progress in mitigating and minimising modern slavery in its business operations and supply chains. • the training about slavery and human trafficking available to its staff. Again, the statements reviewed suggest a variable approach to training across the sector. At one extreme, one statement made no reference to any training delivered or to whom. At the other extreme, one statement made reference to relevant training that is required to be completed by all staff, which is delivered by an e-learning module renewable every three years. There was a more common middle ground referred to in a number of statements, with training provided to and/or undertaken by procurement teams. There was little evidence of wider targeted training to specific departments and employees. In some cases, training on modern slavery and human trafficking has been integrated as part of existing procurement training modules rather than separate and standalone training. There were some references to training events provided to suppliers, albeit by exception. It is noted that generally training references are made almost exclusively in the context of staff/employees as opposed to also incorporating explicitly, or at all, other types of stakeholders such as students, business partners, funders, research collaborators and so on. Informed by the assessment of the institution’s business operations

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