Modern slavery statement

Statement for financial year ending 31 July 2023

Introduction

The Modern Slavery Act 2015 (“act”) was introduced to help eradicate slavery, forced labour and human trafficking in the operations and supply chains of companies. This statement is made pursuant to Section 54, Part 6 of the Act and includes information about the Jisc Group, its own operations and supply chains, and how we are approaching the eradication of slavery and human trafficking within our business.

Our commitment

Jisc is committed to preventing and mitigating exploitation, bribery and corruption. We will not accept modern slavery, forced labour and human trafficking anywhere within our operations or supply chain. We are committed to undertaking a risk analysis of our supply chain to further develop a plan to improve transparency and accountability in our supply chain. A dedicated working group has oversight of our approach to combatting modern slavery.

Our commitment is set out in further detail in our modern slavery policy (pdf).

Jisc Group structure

The Jisc Group includes Jisc as the parent company with three active subsidiary companies - Jisc Services Limited, Jisc Commercial Limited* and Jisc International Singapore Pte Limited.

Jisc is the only company in the Jisc Group which is required to produce a Slavery and human trafficking statement, though the risk areas and activities outlined in this statement apply equally to all companies in the Jisc Group.

What Jisc does

We are the UK’s digital, data and technology agency focused on tertiary education, research and innovation.

We deliver e-infrastructure services, solutions to enable education and research, advice and guidance and new solutions through research and development. Our work is UK wide, providing services and support to universities, colleges, schools, research institutes and many other national institutions. We are a membership organisation, working to deliver considerable collective digital advantage, financial savings and efficiencies for our members, ensuring these benefits are sustained and enhanced and to do all this as affordably, efficiently and as cost effectively as possible.

Jisc operations

We directly employ 1247 staff as a combination of office-based staff and home-workers. We are confident that our own operations are free of modern slavery, forced labour and human trafficking. Colleagues across the Jisc Group work under comparable terms and conditions that are in accordance with UK employment law, and we are an accredited Living Wage Employer. Health, safety and well-being support is in place for all staff including access to a network of Mental Health First Aiders and specialist counselling support.

Policies

We have a range of employment policies in place which ensure that our employees are fairly treated, supported, remunerated and understand the behaviour expected by the organisation. Our refreshed and updated Equity, diversity and inclusion (ED&I) policy was launched in February 2023. Our employment policies are listed in our modern slavery policy and are available on request.

Supply chains and risk areas

We have a team of procurement specialists managing procurement processes. The suppliers we use to deliver our activities, and our own operations, are primarily EU based.

We contract with a range of suppliers, from large international IT companies to local cleaning and catering companies. Our risk analysis of our supply chain is allowing us a better understanding of supply contracts where there is a greater risk of exploitation.

We also create, negotiate and have access to a series of frameworks - umbrella agreements put in place with a group of suppliers who fit certain criteria and in accordance with the EU public contracts regulations 2015. These frameworks are available to our members, who rely on us to have completed modern slavery compliance checks on suppliers. We are exploring how we can improve our oversight of these suppliers.

We acknowledge that some of our supply chains involved in the mining of some rare earth materials (such as cobalt) required to produce computer hardware and devices are untraceable and that there are limitations in understanding the degree of the risk of exploitation.

Our modern slavery policy describes supplier obligations in reporting breaches of the modern slavery regulations and Jisc’s whistleblowing policy explains how members of staff can also report breaches.

Due diligence

As part of our approach to maintaining a supply chain that is free of modern slavery, forced labour and human trafficking, we require commercial organisations meeting the criteria within the Modern Slavery Act 2015 to provide a copy or link to their anti-slavery statement. Our own modern slavery policy is shared with suppliers during procurement processes. We have rolled out a self-assessment questionnaire to all suppliers identified within our high-risk areas and will monitor how this can be rolled out further or where additional due diligence checks need to be implemented. Relevant advice and support will be sent to organisations that have returned a self-assessment questionnaire where there are gaps or opportunities to improve their organisation’s modern slavery commitment.

Through our standard contract we require suppliers to report any breach or suspected breach of the Act associated with our contract to us immediately. We reserve our rights to terminate contracts with suppliers in the event that there is evidence of non-compliance with the Act. Opportunities to develop our approach further are being reviewed.

Responsible recruitment

With guidance from Unseen (a modern slavery charity), we reviewed our recruitment processes to ensure we are doing all we can to mitigate modern slavery. We have focused on raising awareness and incorporating this into our interactions with candidates at the hiring and onboarding stage.

We are reviewing how Jisc can develop opportunities to support modern slavery survivors and, in the future, plan to explore effective partnerships to guide us on how to support victims. This may include how to support victims with interview practice or how to become “work-ready” e.g. with digital skills or/and English speaking practice

Training and awareness raising

Awareness raising amongst our employees is key to ensuring that risk areas are recognised, and employees know what to do if they become aware of any concern associated with exploitation. All staff are required to complete a mandatory modern slavery awareness training course on our training platform and repeat this every two years. The modern slavery policy and this statement are also actively shared with all staff to help colleagues understand their responsibility as individuals to report behaviour which they believe suggests a breach of the Act. Our whistleblowing policy includes appropriate guidance for staff in reporting any suspicion of inappropriate or illegal behaviours.

In addition, a new intranet page has been launched to support staff with queries around modern slavery. This includes identifying signs of possible modern slavery and how to report it. The page also includes a summary of the modern slavery mandatory training course and team discussion points.

Procurement staff are trained annually through the Chartered Institute of Procurement and Supply (CIPS). We have also rolled out further modern slavery training from HEPA for individuals in Jisc teams (legal, governance, procurement and facilities) that deal specifically with high risk suppliers. This is available to all members of these teams that deal with supply chain management.

Collaboration and partnership working

Building effective partnerships and strategic alliances with frontline organisations to guide us in our future plans will be an ongoing action we will begin to explore to progress our community support and modern slavery objectives as an organisation.

Actions in the last reporting year

In the last reporting year:

• A dedicated cross-organisation modern slavery working group continued to operate to assess risk areas, implement improvements and monitor progress against our modern slavery objectives and policy
• We shared our 2022 modern slavery statement through the Home Office modern slavery registry
• We completed a Net Positive toolkit which identified where we can do more to address modern slavery
• We continued to support Unseen, a UK-based charity working towards a world without slavery our corporate charity of the year for 2022. We continue to work with them to see where we can support with volunteering and use of our office space
• We updated our annual supplier check programme to include reviewing our supplier’s modern slavery statements
• We maintained our affiliate membership of Electronics Watch, a monitoring organisation to audit the supply chain of technology components
• We agreed sustainability as a priority programme and will dedicate resource to support the launch of a sustainability strategy
• We rolled out our self-assessment questionnaire to all high risk suppliers via contract managers. Returned questionnaires are reviewed to see where there is opportunity for Jisc to support and advise smaller organisations to be more compliant
• We have shared our modern slavery policy with suppliers and requested that they cascade it to their employees and upload their statements onto the Gov.uk site
• We reviewed contractual provisions around modern slavery and updated accordingly
• We continued to update our sustainability Intranet page with a dedicated section in relation to activities and actions Jisc is taking in relation to our modern slavery objectives and policy

We have not received any reports of potential or actual breaches of the Act and no procurements or contracts have been terminated as a result of concerns regarding compliance with the Act.

Future plans

In the coming financial year (from 1 August 2023 to 31 July 2024), we will:

• Review how to engage with our suppliers about modern slavery – reviewing self assessment questionnaires from high risk suppliers and bid submissions, and working with suppliers to advise and support where appropriate
• Consider how to develop opportunities to support victims of modern slavery
• Continue the risk analysis of our supply chain as we gather more data through new business bids and continue ongoing reviews of our existing supply chain to identity areas for improvement via the modern slavery self-assessment questionnaire
• Continue to explore enhanced training for the departments overseeing high risk area suppliers to raise further awareness, and roll out more widely as we believe is necessary
• Continue working with Electronics Watch to gather and review supplier information.
• Identify risks in new procurements using the Policy Procurement Notice (PPN) Tackling Modern Slavery in Government Supply Chains table of characteristics and complete appropriate checks on subcontractors.
• Review supplier’s modern slavery statements regularly to assess existing suppliers and aim to request these annually from suppliers
• Continue to raise awareness of modern slavery within Jisc via our learning platform, presentations at staff meetings and via the Jisc procurement team

*Jisc Commercial Limited will be closed in 2023-24.