Statement on Eradicating Modern Slavery in Supply Chains

For calendar year January to December 2025 

Issued pursuant to Section 54 of the Modern Slavery Act 2015 

The Modern Slavery Act 2015

As part of The Open University’s commitment to create a society where people are treated with dignity and respect, we publish an annual statement to be transparent about what the University is doing to help eradicate modern slavery. 

Slavery in the 21st century: 

Slavery isn’t a historical relic. Recent global estimates indicate that it is on the increase, with 49.6 million people living in modern slavery in 2022. Of these people, 27.6 million were in forced labour and 22 million were trapped in forced marriage.  Although modern slavery can exist in any supply chain, it has been identified that manufacturing, construction, agriculture, and hospitality are higher risk supply chains. 

In quarter June 2024 , April to June 4,316 referrals were made into the UK National Referral Mechanism. This represents a 5% decrease compared to the period from Jan to March 2024 (4,521)  

73% (3,142) were male and 27% (1,167) were female. this was the second highest quarterly number of referrals for females since the NRM began.   

About the Open University: 

The Open University, founded in 1969, has a mission to be open to people, places, methods, and ideas. Our vision is life-changing learning that enriches society. We promote educational opportunity and social justice by providing high-quality university education to all who wish to realise their ambitions and fulfil their potential. The Open University’s core values are to be inclusive, to innovate and to be responsive.  

Our Supply Chain 

Procurement Services use a range of data to assess supply chain risk. In 2023-24, the University spent over £29m out of a total of £140m on goods and services from over 3,000 suppliers, which were deemed high risk for Modern Slavery.  The highest risk areas in the procurement of goods and services were: 

• Temporary and Recruitment Employment Agencies (People Services)
• Building Repairs and Maintenance Services (Estates)
• Courier Services (Estates/Learning Discovery Services)
• Cleaning Services (Estates)
• Desktop, Laptop, Tablet, Computer Purchase (Digital Services)
• Laboratory Equipment (STEM) 

What we are doing to eradicate modern slavery in our supply chains: 

All staff are required to act in accordance with The University Equality Scheme 2022-2026. It ensures all staff create an inclusive university community and a society where people are treated with dignity and respect, where inequalities are challenged and where we anticipate, and respond positively to different needs and circumstances so that everyone can achieve their potential. It is in this context that we have based our approach to eradicating modern slavery in our supply chains. 

In our procurement activities, The Open University are members of the Southern University Purchasing Consortium (SUPC). Through this consortium and other public sector organisations the Open University uses framework agreements which also commit to eradicating modern slavery.  The SUPC statement is here. 

SUPC Modern Slavery Statement

Since 2017 The Open University has: 

1. Published and enacted a Modern Slavery Policy,  updated in 2023.
2. Requested information from our major suppliers in high risk spend categories.  
3. Updated The OU Procurement policy to specifically address modern slavery and wider equality and diversity in 2023.
4. Updated procurement processes and tender documentation to ensure the risk of modern slavery is considered.
5. Guaranteed that at least the National Living Wage is paid by the OU contractors for high-risk areas: catering, cleaning, and guarding services.  3 The OU is an accredited National Living Wage Employer, committed to paying a wage based on the cost of living to all their staff.
6. Provided guidance and support to staff involved in major procurement projects and developing guidance for smaller contracts.
7. Put in place a Whistleblowing Policy (effective December 2021) which encourages staff to highlight concerns of malpractice. The OU adheres to the Public Interest Disclosure Act 1998.
8. Put in place recruitment policies and procedures which provide advice on fair, efficient and effective practice in the recruitment and selection of all categories of staff.
9. Ensured Modern slavery awareness online training is completed by staff in high-risk areas: Procurement, Estates, and IT.
10. Introduced use of The Sustain Supply Chain Code of Conduct (last updated 2021), allowing the OU to gain commitment and compliance from suppliers, with respect to their own organisation and supply chain.
11. The OU’s Modern Slavery working group has continued to meet on a quarterly basis, with representation from all key areas.  

Achievements for 2024: 

• Continued to engage suppliers to sign up to the Code of Conduct and Netpositives supplier tool,  
  • 425 suppliers (£57m) who have signed the Sustain Supply Chain Code of Conduct.
  • 128 suppliers (£69m) signed up to NETpositive Supplier Engagement – NETpositive Futures.  
• Included an introduction to modern slavery within the OU’s induction training for all new staff
• Rolled out refresher training to staff in high-risk category areas; Digital Services, STEM faculty, People Services and Estates. 78 staff identified, 30 have completed the training which is approx. 40%.
• Reviewed our work, in line with the statement framework published by the Ethical Trading Initiative. The OU’s Code of Conduct was mapped to the 9 pillars of the Ethical Trading Initiative.
• Published our annual statement to the UK government’s Modern slavery statement registry.  

In 2025 the Open University will: 

• Continue to encourage staff in high-risk category areas to complete training.
• Extend use of NETpositive supplier engagement tool and Sustain Supplier Code of Conduct.  
• Demonstrate progress against the statement summary section of the Modern slavery statement registry to comply with policies and modern slavery risks.
• Consider how to align our activity with the University’s EDI and Sustainability initiatives. 

Any breaches of the policies outlined in this Statement may result in the University taking disciplinary action and/or terminating its relationship with an organisation or supplier. 

Signed by: 

Professor. Josie Fraser  
Interim Vice-Chancellor 

Governance and Document Control