Anti-Slavery and Human Trafficking
Introduction from Chief Executive Peter Phillips
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. This statement, made in accordance with section 54 of the Modern Slavery Act 2015, summarises our current approach and sets out the action we plan to take in the coming year in our business and our supply chains.
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 visit cambridge.org/about-us.
Our Policies on Slavery and Human Trafficking
To further our commitment to combating modern slavery and human trafficking, we have taken the following steps:
- In April 2016 we released a new Anti-Slavery and Human Trafficking Policy and Framework to all Press employees which outlines our zero-tolerance to modern forms of slavery and human trafficking, and reflects our commitment to acting ethically and with integrity in all of our business relationships
- Our Code of Ethics has been updated to include a modern slavery section
- The Policy and Framework will continue to be monitored and reviewed
Risk Assessment Processes
As part of our initiative to identify and mitigate risk, we have carried out the following risk assessments to date:
- We conducted a detailed analysis of our global third party community, which is made up of many thousands of suppliers and distributors. The majority of spend is with around 2,000 of these.
- We risk assessed these 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
The results of the risk assessment highlighted the following about the risk levels in our supply chain:
- High risk: Primarily printers, typesetters and distribution partners (approximately 3 per cent of our third party base)
- Medium risk: In addition to the above, certain IT, supply chain and facilities providers (approximately 12 per cent)
- Low risk: A mix of the above, plus other third party types such as digital distributors, marketing suppliers, and internal suppliers, to include legal service companies, accounting firms, IT infrastructure suppliers, etc. (the remaining 85 per cent)
- No risk: Authors and freelancers (being individual suppliers)
Due Diligence Processes
The risk assessment processes we have carried out and will continue to carry out will inform our approach to due diligence. The steps we have taken to update our current due diligence processes are outlined below:
From July 2016 onwards, new third party relationships will be subject to the following:
- More extensive questioning around compliance with international labour law to include specific questions about modern forms of slavery and trafficked labour
- Updated contractual terms to include modern slavery provisions
- A new Third Party Code of Conduct
- Existing high risk relationships will be asked to re-certify our Code of Ethics annually, while those deemed medium and low will be contacted every two years
- Increasing our industry-wide engagement on these issues, including setting up a new Compliance Committee at the UK Publishers Association and strengthening our relationship with the Publishers Resolution for Ethical International Manufacturing Standards (PRELIMS), a collaboration of UK and US publishers who have been working together to develop a common process to assess labour and environmental standards
To raise awareness of modern slavery and human trafficking risks in our supply chain and our business we provide training to our employees. Our anti-trafficked labour training programme was released in May 2016 and combines online training for all employees, with face-to-face training for those in senior or front-line roles.
Measuring Effectiveness – Key Performance Indicators
In order to monitor our effectiveness in preventing modern slavery and human trafficking from taking place in our business and supply chains, we have started to measure our progress against the following key performance indicators (KPIs):
- Keeping our Anti-Slavery and Human Trafficking Policy updated and under review
- Employees signed up to or re-signed to our Code of Ethics
- Employee and third-party training
- Number of risk assessments of third parties carried out
- Due diligence completed
- Audit processes
- Partnerships entered into with organisations such as PRELIMS
This statement 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. It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 May 2015 to 30 April 2016.
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.