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Anti-Slavery and Human Trafficking Statement
Introduction from Chief Executive Peter Phillips
This statement, made in accordance with section 54 of the Modern Slavery Act 2015, summarises Cambridge University Press’s activities during financial year 1 May 2016 to 30 April 2017 with regards to combating Modern Slavery in its supply chain. Cambridge University Press has a zero tolerance approach to Modern Slavery and we are committed to acting ethically and with integrity. This includes a commitment to upholding the standards set out in the Modern Slavery Act 2015 and to implementing systems and controls to ensure that Modern Slavery is not taking place anywhere within our organisation, or in any of our supply chains. The Press’s most significant suppliers include printers, typesetters and distribution partners; our supply chain also includes IT suppliers used for both back office and front office systems, third party advisors such as tax and legal advisors, and third party contractors and freelancers who help supplement our traditional workforce with office services and as marketing suppliers. We find that for the purposes of the Modern Slavery Act, the majority of our focus is on the typesetters, printers, and distributors.
The Press plays a leading role in today’s global publishing market place. We have over 50 offices around the globe, and distribute our products to nearly every country in the world. To find out more about what we do and our mission statement, please go to www.cambridge.org/about-us/what-we-do/.
Our Policies on Slavery and Human Trafficking
As noted in our previous annual statement, our Anti-Slavery and Human Trafficking Policy was launched during May 2016, and since then, our Code of Ethics and Third Party Code of Conduct have included sections on the standards expected of employees and third parties with regard to combatting modern forms of slavery. For our Code of Ethics please go to www.cambridge.org/gb/about-us/who-we-are/cambridges-ethics. There are nine standards that we expect of both our employees and third parties relating to labour standards within the Press and our extended supply chain. During May 2016 all employees were asked to review the Code of Ethics that included the new Modern Slavery section and related internal policies. Employees also completed training on this new policy area. All applicable third parties have received and have been asked to sign up to the Third Party Code of Conduct before being engaged by the Press since this time. Our ethical policies for employees and third parties include provisions for raising concerns, via internal contact points, and via an external whistleblowing hotline.
Risk Assessment Processes
We risk assess third parties based on their main country of operations using various global assessments1 of human rights and human trafficking risks by country, spend level, third party type, as well as internal knowledge of the company in question and its ongoing supply chain. Our risk assessments continue to find that our high risk third parties from a Modern Slavery perspective are primarily typesetters, printers and distribution partners. More information on our risk assessment and due diligence findings are noted below in our KPI section.
Due Diligence Processes
Since July 2016 onwards, our due diligence procedures for new third party relationships include the following:
- More extensive questioning around compliance with international labour law to include specific questions about modern forms of slavery and trafficked labour.
- Contractual terms to include modern slavery provisions.
- A new Third Party Code of Conduct.
- Existing high risk relationships are asked to re-certify our Third Party Code of Conduct annually, while those deemed medium and low are contacted every two years.
- We have also started trialling a new audit process for the highest risk third parties, and plan to expand this activity in financial year 2018.
Since May 2016, all Press employees have been asked to complete modern slavery training to ensure broader awareness about modern slavery and human trafficking risks in our supply chain.
Measuring Effectiveness – Key Performance Indicators
Please see below an update on key performance indicators (‘KPIs’) that the Business continues to monitor related to our Modern Slavery Act activities:
- Keeping our Anti-Slavery and Human Trafficking Policy updated and under review:
- Since May 2016 we have had over 2,800 existing employees, contractors and agency sourced colleagues re-sign and 660 new colleagues sign up to our Code of Ethics, with the new Modern Slavery policy section included.
- Employee and third party training:
- In May 2016, the same colleagues who signed up to our Code of Ethics were also trained on the topic of modern slavery, with again over 660 colleagues who have joined the Business since May 2016 completing the same training
- Slavery and Human Trafficking Risk Assessment and Due Diligence of Third Parties:
- Any third party who signs up to our Code of Conduct is asked to comply with our standards relating to anti-human trafficking and modern slavery. Last year, we reported that 3% of our third party base was deemed higher risk. These were primarily typesetters, printers and distributors. Following further analysis and dialogue with the majority of these organisations, we have been able to determine that the risk is lowered because they have answered our questions to confirm they have the proper controls in place related to modern slavery issues and that they have agreed to uphold our modern slavery standards. A small number of responses remain outstanding as at the date of publication and we will continue to monitor and assess these potentially higher risk third parties. Since last year, we have engaged various new third parties, and based on the risk assessment alone, a further 59 third parties were deemed high risk based on a combination of bribery and corruption and modern slavery factors. All of these third parties were asked to sign up to our Code of Conduct, which includes modern slavery standards, as well as responding to questions related to modern slavery risk that would mitigate the inherent risks. Based on an overall review of our third party networks and re-ranking of some of our existing third party base, we now have less than one per cent of our third parties deemed as high risk. In the next year, we plan to complete our high-risk third party reviews, and focus on our medium risk third parties.
- Partnerships entered into with organisations such as Publishers Resolution for Ethical International Manufacturing Standards, (PRELIMS):
- No new partnerships were entered into although we have expanded our work with PRELIMS since last year.
- Audit processes:
- During the past three months, Press employees have conducted three modern slavery audits on high risk printers; a further four printers have been externally audited to Sedex Trade Members Ethical Trade Audit, (SMETA), ethical audit formats, and one has been audited by PRELIMS. This covers 70 per cent of our highest risk third parties by value of spend. No adverse findings were found in any of these audits, although some recommendations on labour best practices were provided.
- The Press’s aim is to have all our printers audited within the next year, whether by internal means or external organisations. The audit includes a combination of the third parties responding to questionnaires or providing other documentary evidence to confirm their adherence to certain standards, as well as observing labour standards on site.
This statement, made in accordance with section 54 of the Modern Slavery Act 2015, is made by Cambridge University Press, a Department of the University of Cambridge, and has been approved by the organisation’s Press Board who will review and update it annually.
1. The reports that were reviewed included the 2015 US State Department Trafficking in Persons and Workers Rights Report, the Global Slavery Index 2014, the Labour Exploitation Legal Resources, and the Corruption Perceptions Index 2014.