Modern Slavery Statement

In line with the Modern Slavery Act 2015, this is our modern slavery and human trafficking statement.

It sets out:

• Who we are as an organisation and what we do.
• Where we believe our risks of slavery and human trafficking exist.
• How we currently manage those risks.
• What further steps we are taking to ensure we continue to manage those risks.

The Scottish Further and Higher Education Funding Council is Scotland’s tertiary education and research authority, and our purpose is to sustain a world-leading system of tertiary education, research and innovation that enables students to flourish, changes lives for the better, and supports social, economic and environmental wellbeing and prosperity.

As a non-departmental public body established by the Further and Higher Education (Scotland) Act 2005, we are directly accountable to Scottish Government Ministers and the Scottish Parliament. We work across many government portfolios and are sponsored by the Lifelong Learning Directorate.

We hold colleges, universities and other funded bodies to account for their delivery of required outcomes. We are also the statistical authority for colleges, and work closely with the UK-wide Higher Education Statistical Authority (HESA), to provide data and statistics for government, decision-makers, and the wider public.

We work in partnership with a wide range of partners and bodies, including those we fund, across all aspects of our remit.

We employ 157 people[1] in a variety of professions, from data analysis to policy development and financial expertise.

We are committed to building a diverse workforce which is representative of the communities we serve across Scotland and to creating a working environment in which unique perspectives are celebrated and everyone can bring their whole selves to work. Our recruitment practice follows the principles of the Office of the Civil Service Commissioners Recruitment Code which means we recruit on merit on the basis of fair and open competition, and we are proud to embrace the principles of Fair Work in our employment policies and practices.

[1] As at 31 March 2024.

We recognise that modern slavery is a significant global human rights issue and includes human trafficking, forced and bonded labour, child labour, domestic servitude, and sex trafficking. We are committed to protecting and respecting human rights and have a zero-tolerance approach to slavery and human trafficking in all its forms. We will act ethically and with integrity in all our relationships and use all reasonable endeavours to take action directly and to influence others to ensure slavery and human trafficking is not taking place, wherever we can do so.

Our Human Resources policies set out our commitment to workplace rights at SFC. Our ‘Dignity and Respect at Work’ policy promotes an enabling and inclusive environment in which all members of the SFC community are treated with dignity and respect, and bullying, harassment and discrimination are known to be unacceptable. Underpinned by our Staff Code of Conduct, we are committed to fair, progressive, and ethical working practices and we have in place policies on anti-bribery and corruption as well as counter fraud and financial conduct. We also have a Public Interest Disclosure (“Whistleblowing”) policy which enables staff to report improper conduct or unethical behaviour.

We have a number of policies which govern our relationships with businesses, including an SFC Procurement Policy which displays our principles and practices in the acquisitions of goods, services and works, and outlines how we will take steps to ensure an ethical procurement approach including promoting payment of the Scottish Living Wage. It takes its lead from the comprehensive Scottish Procurement Policy Handbook available on the Scottish Government website.

We comply with the provisions of the Ethical Standards in Public Life (Scotland) Act 2000. We require all of SFC’s Board members to complete a Register of Interests which is updated regularly and is available to the public.

We also seek to comply with On Board: A Guide for Board Members of Public Bodies in Scotland which sets out the responsibilities of Boards of public bodies and their members, and provides good practice in corporate governance. We also seek to comply with the relevant provisions of the Financial Reporting Council UK Corporate Governance Code.

Employees, customers or other concerned parties can also refer to the UK National Helpline at www.modernslaveryhelpline.org or call 0800 012 1700.

The commitment to ethical standards and integrity at the corporate and strategic level informs the procurement activity within SFC. SFC seeks to identify, prevent and mitigate the risks around modern slavery in its supply chains.

Measures included within the Procurement Reform (Scotland) Act 2014 and the Public Contracts (Scotland) Regulations 2015 and are embedded in all of our procurement activities and relevant Scottish Procurement Policy Notes (SPPN 3/2020) are circulated to relevant staff and implemented where required.

SFC is a member of Advanced Procurement for Universities (APUC Ltd), the procurement centre for expertise for Scotland’s universities and colleges. A significant proportion of SFC’s procurement is through collaborative Framework Agreements established by APUC or other sectoral and national purchasing consortia. Typically, consortia manage sustainability risks related to these frameworks. Procurement activity outside of this is managed by our procurement function, which includes resource provided as part of an APUC shared service.

SFC is a Consortium Affiliate to Electronics Watch through APUC. APUC was a founding member of Electronics Watch which is a collaborative organisation addressing labour rights issues in ICT supply chains.

While the risk of modern slavery in our direct activities is likely to be low, we recognise that there are risks through the goods and services that we procure linked to supply chains around the world.

We buy a limited range of goods and services, including consultancy, IT solutions, furniture and stationery, electronics (computers, audio visual, etc.), catering services, and travel services, and do so in accordance with public procurement legislation.

For any procurement activity outside of collaborative framework agreements there is an appropriate level of sustainability risk assessment undertaken. This risk assessment informs the overall business case or contract strategy and should highlight Modern Slavery risks. SFC will aim to mitigate risks through design of the specification, supplier selection, tender evaluation and contract management stages of the procurement cycle. SFC will also seek to review its spend profile periodically to highlight any potential sustainability risks.

Given the global reach of the institutions we fund, we recognise that there are potential risks of modern slavery occurring related to their activities around the world, especially when located in high-risk countries.

We work with colleges and universities, procurement bodies such as APUC, and government agencies to inform and mitigate risks, and the conditions of our core grant funding include information on our expectations towards the institutions we fund. This includes an expectation for:

• A commitment to Fair Work practices for staff (including any agency or sub-contractor workers) engaged in the delivery of activity associated with public funds.
• A statement on Fair Work practices that has been developed in agreement with the institution’s workforce.
• A brief commentary in an institution’s Strategic Report outlining the Fair Work practices that have been developed in agreement with their workforce and the progress the institution has made in their implementation.

We are signatories to the Concordat to Support Research Integrity. Through our Outcomes Framework and Assurance Model we expect all institutions in Scotland to commit to comply with the concordat. This includes the submission of an annual statement to UUK.

Preventing modern slavery on our own premises. We are rigorous in checking that our staff have the right to work in the UK. Where it is necessary to hire agency workers or contractors, we utilise specified, reliable agencies who have met SFC’s rigorous procurement procedures regarding their business and employment policies and practices.

SFC pays its staff the Real Living Wage and is accredited by the Living Wage Foundation. SFC evaluates potential suppliers who will be working with us, in person or remotely, on their approach to Fair work Practices, including the Real Living Wage.

Excluding any suppliers which have been convicted of offences of child labour or other forms of trafficking in human beings. Every regulated procurement process conducted by SFC requires tenderers to disclose whether the bidder or any member of their organisation with decision-making powers has been convicted in the last five years of any offence under Part 1 of the Human Trafficking and Exploitation (Scotland) Act 2015, or under any provision referred to in the Schedule to that Act. Tenderers that confirm such a conviction will be excluded from the process unless they can sufficiently demonstrate reliability of changes to their practices.

Listening to and protecting whistle-blowers. SFC adheres to The Public Interest Disclosure Act 1998 and implements its own ‘Whistleblowing’ policy regarding concerns about corruption, fraud or other malpractices within SFC.