This is LSTM Group’s statement for the financial year 2017-18.
Introduction from the Director of LSTM
The Liverpool School of Tropical Medicine (LSTM) recognises that all organisations have an obligation to prevent slavery and human trafficking. Modern Slavery is an international crime affecting millions of people across the globe. It is an unacceptable practice involving people regardless of age, gender or ethnicity in developed (including the UK) as well as developing countries. Within Britain victims include people trafficked from overseas, or vulnerable people from the UK, who are forced to work illegally or against their will.
The purpose of this statement is to satisfy part 6 of the Modern Slavery Act and to provide an update on our commitment to ensuring that our supply chains are free from slavery and human trafficking.
1. Organisation’s Structure
LSTM, founded in 1898, is the oldest school of tropical medicine in the world and is an internationally recognised centre of excellence for teaching and research in tropical diseases. Through the creation of effective links with governments, NGOs, private organisations and global institutions and by responding to the health needs of communities, LSTM aims to promote improved health, particularly for people of the less developed/resource poorest countries in the tropics and sub-tropics.
In 2013 LSTM was awarded the status of a Higher Education institution and in 2018 the Privy Council granted to LSTM degree awarding powers.
The LSTM Group consists of:
- Liverpool School of Tropical Medicine - comprising of academic departments, research centres, administrative departments and libraries.
- LSTM also has an interest in the following NGOs;
LSTM DRC, Liverpool Initiative for Health Development (Nigeria), LSTM Sierra Leone, LSTM Malawi, LSTM Uganda, LSTM Tanzania (Ltd Company), CeSHHAR Zimbabwe (Charity)
- LSTM Consulting – Providing technical assistance on health issues in tropical countries with interests in the following active companies and NGOs;
LSTM Kenya, LSTM Consulting USA, LATH South Sudan (NGO).
- IVCC - a not-for-profit public-private partnership that was established as a charity in 2005.
- Well Travelled Clinics - a trading company, a centre of excellence, providing a private pre-travel advice, vaccination and malaria prophylaxis service to the travelling public of the northwest of the UK.
- Liverpool School of Tropical Medicine Foundation India
In 2017-18, for the tenth successive year the LSTM Group was able to report a record level of income, exceeding £200m for the first time in LSTM’s history. The LSTM group has a global reach in the activities undertaken and a network of 532 staff across the globe to deliver this work. LSTM taught around 800 students in 2017-18 and has an ambitious plan for growth within the education provision for the future. As the LSTM Group continues to grow, the work on modern slavery has begun to increase with the formation of a Modern Slavery working group and creation of a Modern Slavery Action Plan.
Our Supply Chains
We are working to map our supply chain and develop our understanding of the suppliers across the world. We have a global supply chain, with around 20% of our frequently used suppliers based outside of the UK.
Over the last 12 months we have:
- made staff and suppliers aware of the Modern Slavery Act 2015 through the introduction of new terms and conditions and promotion through the Procurement training sessions.
- Performed risk assessments on our partners and suppliers.
- Revised our terms and conditions to include relevant Modern Slavery Act provisions.
- Amended our Public Interest Disclosure Policy to include Modern Slavery Act.
Our Supplier base has been broken into 5 categories for which a Category management strategy is produced for the effective monitoring of activity in these areas. The categories are: Computing and AV, Office Solutions, Laboratory and Medical, Estates and FM, and Professional Services. The procurement team are working on strategies to improve the value for money and manage the modern slavery risks within each of these categories. These strategies will be completed over the next 12 months and are incorporated into the Modern Slavery Action plan for 2018-19.
2. Our Policies on Slavery and Human Trafficking
We are committed to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. LSTM Group operates to ensure fairness in the recruitment, retention and development of employees and it seeks to comply with all applicable employment legislation. LSTM Group seeks to provide a work environment where employees are treated with respect, dignity and consideration.
Our Supplier Code of Practice sets out our expectations to our suppliers. It is published on our webpages and will be reviewed in the next 12 months. https://www.lstmed.ac.uk/about/procurement/supplier-code-of-conduct.
A new Safeguarding Policy was produced in 2017-18 following consultation and extensive assessment of the risks faced by LSTM Group. (https://lstmed.sharepoint.com/policies/PoliciesProcedures/Safeguarding%20Policy.pdf) This new policy was shared with all staff and partners. All staff also received the revised LSTM Code of Conduct. (https://lstmed.sharepoint.com/policies/PoliciesProcedures/Code%20of%20Conduct%20LSTM.pdf).
The LSTM Public Interest Disclosure (whistleblowing) policy is available to all staff and devised to enable all members of LSTM to raise concerns at an appropriate level and is in line with the legal requirements contained within the Public Interest Disclosure Act. https://lstmed.sharepoint.com/Departments/HR/Policies%20and%20Procedures/Whistleblowing.pdf
3. Due Diligence Process for Slavery and Human Trafficking
LSTM recognises that slavery and human trafficking risks may exist in supply chains and are committed to taking steps to reducing that risk in the LSTM supply chain by implementing numerous policies and procedures, these include;
- Due Diligence process, procedures and policy under review (due for completion in 2019).
- Public Interest Disclosure Policy (https://lstmed.sharepoint.com/Departments/HR/Policies%20and%20Procedures/Whistleblowing.pdf).
As part of our commitment to identify and eradicate slavery and human trafficking from within our organisation and from those businesses with which we interact, over the past 12 months we have; -
- Worked closely with our supply chains using tools such as the NetPositive Sustainability tool, to ensure compliance with legislative obligations. We expect those organisations to have suitable anti-slavery and human trafficking policies and processes.
- Begun to build long standing relationships with suppliers and to make clear our expectations of ethical business behaviour from them.
- Put in place systems to encourage the reporting of concerns and the protection of whistle blowers.
Within the Procurement process, due diligence is carried out on all tier 1 suppliers prior to their addition to the LSTM Finance system, during a tender process or during the creation of a contract. Over the past 12 months 150 new suppliers have been added to the finance system and have all undergone some element of due diligence. Further due diligence is undertaken on contracted suppliers within the contract review process. The Procurement team plans to extend the contract management process to gain feedback from service users and suppliers through online surveys throughout the contract to deepen our understanding of the supply chain and enable risks of modern slavery to be identified and addressed.
Supplier Adherence to our Values
LSTM has a zero-tolerance view to slavery and human trafficking and we expect that view to prevail in our supply chain and contractors. This is communicated to all LSTM group suppliers through the Supplier Code of Conduct, as above. Senior Managers within LSTM are responsible for compliance in their respective departments, insofar as there is perceived to be a risk of encouraging, engaging or sustaining slavery and human trafficking.
4. Risk Assessment
As a user of a variety of external collaborative procurement framework contracts, the LSTM Procurement department are working closely with the North West Universities Purchasing Consortium (NWUPC), to understand and manage risks through contract management processes. The consortia have made the formal record of supplier site visits available for consortia members. Future site visits will include a visual inspection providing reassurance around working practices including any signs of slavery. We expect to be able to report this in subsequent years.
Over the coming months, consideration will be given to the use of the UN Marrakech approach to assess the risks across each of our procurement categories. This will provide a sound basis to focus our resources and help to identify any actions needed to prevent and mitigate risks in the supply chain.
5. Training for Staff
To ensure appropriate levels or risk awareness in respect of modern slavery and human trafficking, we have to ensure awareness to relevant employees, including Senior Managers in our Procurement department and Human Resources department. All Directors in the organisation have been briefed on the subject. Specific training has been undertaken by our Head of Procurement who has completed the CIPS Ethical Procurement and Supply course and certificate. All staff have access to our Public Interest Disclosure and Whistleblowing code of practice through the LSTM Policy Hub.
6. Our Effectiveness in Combating Slavery and Human Trafficking
As has been stated above, we believe that, because of our position within the Education Sector and our reliance upon direct, one to one recruitment process, with subsequent monitoring of performance and the attainment of performance standard, our exposure within our human resources to human trafficking and slavery is low.
Further improvements are being made to our processes and procedures in the coming 12 months to improve LSTM’s policies relating to Modern slavery and to better understand the LSTM global supply chain and the modern slavery risks we are exposed to.
This statement is made to pursuant to Section 54(1) of the Modern Slavery Act 2014 and constitutes LSTM’s slavery and human trafficking statement for the financial year 2017-18.
Signed by LSTM Director:
Date: February 2019