Slavery and Human Trafficking Statement

City of Glasgow College, Scotland’s largest technical and professional skills college, is committed to preventing modern slavery and human trafficking in all its forms within our institution and supply chains.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking - all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

This statement outlines our commitment and the steps we have taken - and will continue to take - to ensure our compliance with the Modern Slavery Act 2015.

Our Commitment

The College recognises our responsibility to take a robust approach to modern slavery and human trafficking. We are wholly committed to acting ethically, upholding human rights and enforcing effective controls to ensure slavery and human trafficking are not taking place anywhere within our organisation or in our supply chains.

Our Board of Management, the College’s governing body, is committed to delivering high standards of corporate governance. A key element of good governance is ensuring the College operates in a socially responsible way.

The College implements a range of measures, and regularly reviews their effectiveness, to ensure we comply with all applicable laws and regulations and employ the highest ethical and professional standards. We also support the UK Government’s Action Plan to implement the United Nations Guiding Principles on Business and Human Rights.

Our Supply Chain

The College’s supply chains fall under three main categories:

• Estates.
• ICT & Libraries.
• Professional Services.

The principal commodities which carry risks are office supplies, laboratory consumables, ICT equipment and some estates services, such as cleaning and security services. 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 department. If evidence were found indicating modern slavery in our supply chains, we recognise our responsibility to work with others to address this immediately.

Our Policies

We have a range of policies in place, supported by processes, practices and procedures, which reinforce our commitment to human rights and ethical practices and set out how we will minimise the risk of modern slavery and human trafficking, including:

• Procurement Policy: Ensuring ethical procurement practices, outlined below, that prevent exploitation.
• Staff Code of Conduct: Setting expectations for the behaviour of our staff and the College’s values.
• Anti-Bribery & Corruption Policy: Preventing unethical business practices and ensuring transparency in our work.
• Public Interest Disclosure (Whistleblowing) Policy: Encouraging our staff to report concerns about unethical practices, protecting them when they do and investigating matters thoroughly.
• Safeguarding Policy: Protecting vulnerable individuals within the College’s community every day.
• Purchasing Terms and Conditions: Outlining the obligations of the supplier in contracting with the college and the due diligence procedures in place for sub-contractors to the supplier. The College reserves the right to terminate and seek recompense for any contract where the supplier is found to be in breach of the requirements of the Modern Slavery Act 2015.
• EDI Policy: City of Glasgow College is committed to Equality, Diversity and Inclusion (ED&I) and to providing an environment that is free from bullying, harassment, victimisation and discrimination, in which everyone is treated with dignity and respect.

The College has embedded sustainable procurement practices throughout its Procurement Policy and Procedures. Measures included within the Public Contracts (Scotland) Regulations 2015 are embedded in all our procurement activities, and relevant Scottish Procurement Policy Notes (eg. SPPN 3/2020) are circulated to relevant staff and implemented where required.

Advanced Procurement for Universities and Colleges Limited (APUC) is the procurement centre of expertise for all of Scotland’s universities and colleges, taking advantage of opportunities for collaborative procurement. Collaborative tenders are led or jointly managed by APUC on behalf of institutions by working with other purchasing consortia across the UK where it adds value by doing so. The College is a member of APUC and currently utilises APUC’s managed contracts which cover some of the categories listed above. APUC’s Slavery statement.

The College’s Procurement department currently utilises and is committed to the APUC Supply Chain Code of Conduct to underpin all tendering activity and supplier adoption. The APUC Code specifies that suppliers shall not use forced, involuntary or underage labour.

Our Plans for the Future

The College is committed to better understanding its supply chains and working towards greater transparency and responsibility towards people working in them.

Working with our suppliers, we can map out those supply chains which represent a medium to high risk of modern slavery, human trafficking, forced and bonded labour and labour rights violations.

As part of our initiative to identify and mitigate risk, the College commits to:

• Monitor, identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Protect whistleblowers, safeguard vulnerable people and report unethical conduct.
• Where possible, build long-standing relationships with our supply chains to ensure these entities have and follow suitable anti-slavery and human trafficking policies and processes.
• Continue to deliver relevant training and awareness sessions, facilitated by our Procurement department and APUC, to staff.

Key Measures

The Procurement department has put in place key performance indicators to measure effectiveness and demonstrate progress in relation to the College’s obligations to mitigate the risk of modern slavery and human trafficking in our supply chain.

The Modern Slavery Statement has been approved by City of Glasgow College’s Board of Management on 26th March 2025 and will be reviewed at least once annually.