Anti-Slavery and Human Trafficking
Introduction from Chief Executive Peter Phillips
Cambridge University Press is committed to acting ethically and with integrity, and does not tolerate any form of modern slavery or human trafficking. As part of our commitment, we uphold the standards set out in the Modern Slavery Act 2015 by 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, our fifth modern slavery statement, made in accordance with section 54 of the Modern Slavery Act 2015, summarises our current approach and sets out the further action we plan to take in the coming year in our business and our supply chains.
Cambridge University Press (‘the Press’) dates from 1534 and is part of the University of Cambridge. Our mission is to unlock people’s potential with the best learning and research solutions. Playing a leading role in today’s global market place, the Press has over 50 offices across the globe, employing over 2,000 people, and publishes over 50,000 titles by authors from over 100 countries, bringing thousands of subjects and millions of ideas to the world. Our publishing covers a huge range of subjects with professional books, textbooks, monographs, reference works, English language teaching publications, software and electronic publishing. Across the whole of our publishing, from starter-level English language teaching materials for learners worldwide, through curriculum-oriented textbooks and e-resources, to the most specialised academic research outputs, we maintain and extend our age-old reputation for high quality and technologi-cal innovation to meet the needs of our customers, authors and readers across the globe. To find out more about what we do and our mission statement, please visit our website.
Our Policies on Slavery and Human Trafficking
We have a number of policies in place to further our commitment to combat modern slavery and human trafficking. These include the following: Our Anti-Slavery and Human Trafficking Policy outlines our zero-tolerance approach to all 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, which is updated annually, provides guidance on the standards of behaviour to which all our staff must adhere. The Code of Ethics reflects the Press’s commitment to implement systems and controls that ensure modern slavery is not taking place any-where within our organisation or in any of our supply chains. It also states our requirement for relevant third parties to hold themselves and their own relevant suppliers to the same high standards. Press employees are required to certify that they have read and understood the Code of Ethics on an annual basis.
Our Third Party Code of Conduct, outlines the minimum standard of behaviour we expect from all our third parties (including agents, contractors, distributors, joint venture partners and suppliers), and is provided to all our third parties prior to conducting business with them. The Third Party Code of Conduct strictly prohibits the use of modern slavery and human trafficking and reconfirms our Code of Ethics requirement for relevant third parties to hold themselves and their own relevant suppliers to the same high standards.
Our Global Concerns at Work Policy outlines our commitment to making it possible for employees with serious concerns regarding any aspect of their work, the conduct of others or the running of our organisation to report such concerns in confidence and with confidence. It includes specific reference to concerns relating to modern slavery and human trafficking.
Our Whistleblowing hotline builds further on the commitment contained within the Global Concerns at Work Policy by providing not only our employees, but also our authors, customers and other third parties with a clear procedure for addressing any concerns, including those relating to modern slavery and human trafficking.
Our Global Procurement Policy is designed to work with our supply partners and their extended supply chains to minimise negative impacts from trading activities on the environment and local communities. To further the commitments made within the Global Procurement Policy, we have signed up to the most widely recognised industry standards for labour conditions, environmental impact and chemical safety.
Our supply chain
Our product supply chains are extensive and global, with suppliers in over 80 countries. We operate 15 warehouses worldwide, which are managed either directly by the Press or by third party logistics providers. The principal activities included in our supply chain are as follows:
- Procurement of goods and services related to production of printed materials
- Procurement of goods and services not related to production of printed materials
- Production of items ancillary to the production of printed materials including, in particular, toys and textiles accompanying certain educational resources
- Production of digital materials and platforms
- Production of printed materials
Assessment of modern slavery risk within our supply chain
Following review of the principal activities included in our supply chain, we have determined that there are 6 main activities our third parties undertake which could pose a potential risk from a modern slavery and human trafficking perspective:
- Digital editing and typesetting
- Production of items ancillary to the production of printed materials (toys and textiles)
- Production of printed materials
- Supply of electronic devices to the Press
In 2016 we completed a detailed analysis of our global third party community, which is made up of many thousands of suppliers and distributors. We identified that the majority of Press expenditure is with around 2,000 of these third parties. To start with, we prioritised the risk assessment of these 2,000 third parties taking into account our annual expenditure with them, their country risk, and the product/service risk, as well as internal knowledge of the company in question and its ongoing supply chain. The results of this risk assessment highlighted the following about the risk levels within our supply chain:
High risk: Primarily printers, typesetters and distribution partners
Medium risk: In addition to the above, certain IT, supply chain and facilities providers
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. No risk: Authors and freelancers (being individual suppliers)
Due diligence processes
Having established where our risk lies, it is important that we conduct due diligence within our supply chain to understand whether there is evidence of modern slavery and human trafficking, and whether there are sufficient controls in place to prevent it. The steps we currently take to assess modern slavery risk are completed as part of our third party due diligence process. All new third party relationships and any existing third party relationships being reviewed, are subject to the following:
- Questioning around compliance with international labour law to include specific questions about modern forms of slavery and trafficked labour to help us understand:
- the processes our third parties have in place to ensure modern slavery and human trafficking does not exist both within their own operations as well as in their supply chain
- whether they have training programmes in place to ensure their employees are trained to understand ethical concerns and risks in relation to modern slavery and human trafficking
- whether they have discovered instances of modern slavery or human trafficking within their own organisation, or their supply chain, and if so, what steps they have taken to ensure the concerns were addressed
- Contractual terms to include anti-modern slavery provisions
- Signing up to our Third Party Code of Conduct thereby requesting they agree to act in accordance with it, including the modern slavery provisions
As an active participant in the Book Chain Project (BCP), a collaborative effort in the publishing industry to promote a responsible supply chain, we have access to additional information that can be used in our due diligence review. One area of the BCP, PRELIMS (the Publishers Resolution for Ethical International Manufacturing Standards), allows us to ensure that our suppliers who have signed up, meet recognised standards for labour and environmental practice. Engaging with the BCP allows suppliers to share their audit findings with multiple publishers easily; we regularly monitor information uploaded into the PRELIMS database to ensure any new information is reviewed and acted upon where necessary.
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 combines online training for all employees, with face-to-face training for those in senior or front-line roles, such as procurement specialists, and members of staff within Operations and Supply Chain. Our online training course helps to ensure that all employees are aware of our regulatory obligations, and are able to identify any issues in regards to modern slavery and human trafficking and raise them appropriately so that any concerns can be addressed.
All new Press employees are required to complete the online antitrafficked labour training course within 1 month of starting work, as part of their on-boarding process. This process also includes certifying that they agree to abide by the Code of Ethics and provides employees with information in regards to how they can ask questions and raise any concerns.
Measuring effectiveness – key performance indicators
The Press has committed to review its Anti-Slavery and Human Trafficking Policy annually and more frequently if circumstances require it. To help measure compliance and the effectiveness of the policy and, through that, our progress in preventing modern slavery and human trafficking from taking place in our business and supply chains, we use key performance indicators (KPIs) to monitor the numbers of:
- Employees signed up to or re-signed to our Code of Ethics
- Employees and third parties who have completed training
- Risk assessments of third parties carried out
- Due diligence processes completed
- Audit processes completed
- Partnerships entered into with relevant organisations such as PRELIMS
These KPIs were first established in 2015/2016 and we consider whether they are still appropriate as part of our annual review of the policy. In its review this year, the Cambridge University Press Board has concluded that the KPIs remain relevant and is satisfied with the progress against them.
This statement is made by Cambridge University Press, a department of the University of Cambridge, and has been approved by the organisation’s Board. It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 May 2019 to 30 April 2020.