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Modern Slavery Statement 2018

Modern Slavery Statement 2018

1. Introduction

1.1. This statement is made pursuant to Section 54 part 6 of the Modern Slavery Act 2015 and sets out the steps that GSM London Limited (the College) and all companies in the Clipper Group Ltd as set out at the end of this document have taken to ensure that slavery and human trafficking are not taking place in our supply chains or in any part of our business.

1.2. Modern slavery is a crime resulting in an abhorrent abuse of human rights. It is constituted in the Modern Slavery Act 2015 by the offences of ‘slavery, servitude and forced or compulsory labour’ and ‘human trafficking’.

2. About GSM London Ltd

2.1. GSM London is a UK-based, independent provider of higher education. It has been established for over 40 years and employs over 300 permanent staff. GSM London is committed to addressing the needs and preferences of its student population by providing low-cost accelerated and extended degrees to support social mobility and inclusion.

3. Our Supply Chains

3.1. Employment of Staff
3.1.1. GSM London mitigates the risk of modern slavery occurring in its workforce by safeguarding directly employed staff by following rigorous Human Resources recruitment policies and processes.
3.1.2. Temporary staff are recruited through verified sources that have provided GSM London with assurance, via the procurement process undertaken, that they comply with the requirements of legislation concerning the rights and welfare of their candidates and staff.

3.2. Procurement
3.2.1. The central procurement team, led by the Chief Finance Officer, is responsible for managing the supply chain.

3.2.2. The supply chains are split into:
3.2.2.1. IT assets and systems
3.2.2.2. Estates and Facilities
3.2.2.4. Professional Services
3.2.2.5. Travel and Travel Related Services

3.2.3. GSM London has identified key areas which may pose a risk of slavery and human trafficking. These include: IT assets and systems; some estate services such as cleaning, catering and security (all outsourced), office supplies and promotional items.

3.2.4. All suppliers are advised of our Modern Slavery Act ethics and the steps we will take when engaging with new suppliers, contractors and business partners to assess the likelihood of slavery or trafficking existing in those organisations and what measures are already in place to combat those risks. GSM London has zero tolerance to slavery and human trafficking. Any current or potential supplier who does not adhere to our values, or is found not to be compliant, will be suspended or removed from the approved supplier list, and will not be considered for future supply unless they can demonstrate full adherence with the requirements of the Modern Slavery Act 2015 and GSM London’s policies and procedures.

3.2.5. GSM London’s internal tendering and contracting processes include prequalification items that address issues such as living wage or responsible sourcing of materials.


4. Policies in Relation to Slavery and Human Trafficking

4.1. GSM London is committed to ensuring that there is no modern slavery or human trafficking in our supply chains and that any acquisition of goods or services is without instigating harm to others.

4.2. GSM London is currently updating its modern slavery and human trafficking policy which reflects our commitment.

4.3. The implementation and enforcement of effective systems and controls will also be devised to ensure slavery and human trafficking is not taking place in our supply chains.


5. On-going Development of Due Diligence for the Future

5.1. GSM London expresses its commitment to work towards greater transparency and responsibility within and for the people working within its supply chains.

5.2. A focus on tackling modern slavery to protect vulnerable workers and remedy severe human rights violations is a focus for GSM London.

5.3. It is important for GSM London to be transparent and accountable and as such, further due diligence processes and reporting will be created and utilised to improve risk identification for long-term social, environmental and financial performance.

5.4. GSM London will revisit its standard terms and conditions to ensure clauses have been included to cover modern slavery and human trafficking as appropriate.

5.5. Whistleblowing policy - GSM London will encourage all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Staff, customers or others who have concerns can use our confidential helpline.

5.6. GSM London will ensure that all permanent staff and relevant temporary staff complete on-line training courses to understand modern slavery and human trafficking. Those who require additional knowledge will be given specialist training.

5.7. Ensure that GSM London’s Staff Code of Conduct makes it clear to staff the actions and behaviour expected of them when representing the College. The College strives to maintain the highest standards of staff conduct and ethical behaviour.

5.8. GSM London will review the ‘Stronger Together’ initiative to ensure they have thoroughly researched and applied all relevant recommendations.

This statement was approved by the Board of GSM London Ltd and all companies in or associated with the Clipper Group Ltd set out below:
Clipper Group Limited (09094164);
GSM London Limited (01443436);
GSM London Holdings Limited (07477490);
GSM London Services Limited (07477485);
Greenford Facilities Limited (08128860);
GSM London Students' Union (08898808);
GSM Educational Trust (08283337),

Signed for and on behalf of GSM London Limited

Amanda Blackmore,
President & CEO
September 2018