Slavery and Human Trafficking Policy

1. Introduction

This policy is made pursuant to Section 54 part 6 of the Modern Slavery Act 2015 and sets out the steps that Newham College has taken to ensure that slavery and human trafficking are not taking place in our supply chains or in any part of our business.

2. Implementation

BEB is committed to acquiring goods and services for its use without causing harm to others. In doing so, BEB is committed to supporting the UK Government’s approach to implementing the UN Guiding Principles on Business and Human Rights.

In implementing this approach BEB supports the Base Code of the Ethical Trading Initiative:
• Employment is freely chosen
• Freedom of association and the right to collective bargaining are respected
• Working conditions are safe and hygienic
• Child labour shall not be used
• Living wages are paid
• Working hours are not excessive
• No discrimination is practiced
• Regular employment is provided
• No harsh or inhumane treatment is allowed

3. Supply Chains

BEB's supply chains are managed under the following categories:

Administration Curriculum Facilities Management ICT & Telecoms Marketing Personnel Professional Services Travel & Transport

The principal areas which carry material risks are office supplies, consumables, ICT and AV equipment, and some estates services, such as cleaning and security services. Procurement will support Newham College’s approach to the Modern Slavery Act 2015. In particular for these spend categories where risk of modern slavery and human trafficking are more common, due diligence will be undertaken to assess how suppliers minimise the risk of modern slavery and human trafficking occurring in the supply networks.

BEB’s procurements follow one of two pathways: collaborative, through regional HE purchasing consortia, or in-house tendering and contracting. Newham College actively engages with its purchasing consortia to support the inclusion of ethical sustainability, including addressing slavery and human trafficking, in their procurement programmes.

BEB’s in-house tendering and contracting processes include some prequalification clauses which address the London Living Wage, and our major soft service contracts already include this requirement. Our standard terms and conditions have clauses covering modern slavery and human trafficking.
Tenet Education Services use the Responsible Procurement Code as a tool to assess the risks and to monitor progress with mitigation.

4. Monitoring

As part of this reporting exercise in this and the coming years, BEB expresses its commitment to better understand its supply chains and working towards greater transparency and responsibility towards people working on them.

Contractors are required to demonstrate to BEB how they are minimising the risk of modern slavery and human trafficking occurring in the supply networks. BEB  will work with its suppliers to monitor these supply chains that have been identified as a potential risk and take appropriate action as necessary.