This statement sets out The City of Liverpool College’s actions to understand all potential modern slavery risks related to its business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business and supply chains.
This statement relates to actions and activities during the financial year 1 August 2022 to 31 July 2023.
The City of Liverpool College Group recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
The City of Liverpool College Group is absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
This statement covers the activities of The City of Liverpool College and our subsidiary company Shared Education Services Limited. The College has a learner population of approximately 10,000 and a turnover of over £36 million.
The City of Liverpool College Group has a diverse supply chain covering staffing resources and operational activities including, but not limited to, estates management, cleaning, and transport.
The City of Liverpool College Group is aware of its legal responsibility, and ensures that our supply chain complies with the Act. This includes policies, risk assessment, due diligence and training requirements.
The City of Liverpool College has a number of policies that assist in preventing slavery and human trafficking in its operations, including:
• Whistleblowing Policy
The City of Liverpool College Group encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. The Whistleblowing Procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Safeguarding Policy
The City of Liverpool College Group provides advice and guidance to staff that includes references to modern slavery and trafficking in the form of published guidance and formal staff training. The legislation, and its implications for practitioners and students, are clarified in the College’s Safeguarding Policy and is covered in the associated Safeguarding Guidance documentation. In addition, it is fully covered in face to face staff training packages during staff induction and in advanced training offered to key staff.
• Procurement Policy
The City of Liverpool College Group is committed to ensuring that its suppliers adhere to the highest standards of ethics and has reviewed its Terms & Conditions to ensure that existing suppliers are aware of their obligations under the Act and comply where necessary. All new suppliers are vetted for compliance with the regulations as part of the due diligence process. Training is delivered for key staff and budget holders.
Any supplier, or potential supplier, 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. They will not be considered for future supply to the College unless they can demonstrate that these compliance requirements are met.
• Recruitment & Selection Policy
The City of Liverpool College Group uses reputable employment agencies to source staffing requirements. It verifies the practices of any new agency used before accepting workers from that agency.
The College ensures that all approved recruitment agencies conduct all relevant pre-recruitment checks and provide evidence that all such checks have been conducted.
• Anti-Bribery and Corruption Policy
The City of Liverpool College Group 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 operating on its behalf.
The City of Liverpool College Group undertakes appropriate financial and due diligence checks when considering taking on new suppliers, and regularly reviews its existing suppliers to ensure they meet their regulatory obligations.
The New Supplier Application Form requires suppliers to provide evidence that they comply with the Act, and thereby the College seeks assurance.
An analysis has taken place of the current suppliers who meet the turnover criteria, and the College has received assurances that these organisations comply with the Act.
Tender documents include a supplier Suitability Assessment Questionnaire to seek assurance that potential future suppliers comply with the act before entering into new contracts.
The College has introduced performance indicators (KPIs) to measure progress against reducing any risks of modern slavery occurring in any part of our services or supply chain. Progress on KPIs are reported to Board on a regular basis. The KPIs are set out below:
• % key staff (Procurement staff and HR staff) trained in legal background to modern slavery. Target 100%.
• % recruitment agencies demonstrated compliance with Modern Slavery requirements. Target 100%.
• % new suppliers demonstrated compliance with Modern Slavery requirements. Target 100%.
• % existing suppliers demonstrated compliance with Modern Slavery requirements. Target 100%.
This statement will be made available to all staff members, stakeholders and the general public by publication on our website.
The City of Liverpool College Group ensures that key staff undertake training on modern slavery, where deemed necessary, and engages with external training providers, as appropriate.
This statement has been approved by The City of Liverpool College’s Governing Body on 27 June 2023 and will be reviewed and updated annually as part of the review of the Financial Statements.
Principal / Chief Executive Chair of Governors