Modern Slavery Statement

In additional to the Modern Slavery Statement below, a downloadable version of the Statement is also available: Modern Slavery and Human Trafficking Statement Year Ended 2024-25 - please note that this will download/open in a new tab or window.

1. Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another to exploit them for personal or commercial gain.

We are committed to improving our practices to ensure there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 (as amended). We expect the same high standards from all of our contractors, suppliers and other business partners.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (as amended) and constitutes our group’s slavery ad human trafficking statement for the financial year ending 31^st July 2025.

2. Organisational Structure

We are a Higher Education provider based in the United Kingdom, with campuses in Wolverhampton, Walsall and Telford, we have c. 23,600 students within the UK and abroad and c. 1,900 UK based staff.  Our annual turnover in the financial year ending 31^st July 2025 was c. £200m.

The University of Wolverhampton Higher Education Corporation within its group structure has several established subsidiary companies which are either wholly or jointly owned. Further details on the group structure can be found here: https://www.wlv.ac.uk/about-us/governance/legal-information/publications-scheme/who-we-are-and-what-we-do/

3. Use of Recruitment/Agency Workers

The University uses specified, reputable employment agencies to source labour, using a rigorous procurement process, which is committed to assisting in the eradication of unethical business practices including bribery, fraud, corruption and human rights abuses, such as modern slavery and child labour, before it accepts any workers from that agency.

The University appointed Adecco in 2023 to manage UK based Temporary Staff/Agency Workers, this ensures a centrally controlled service monitoring, not only modern slavery concerns but also, payment methods and general management information.

4. Strategy 2035

The mission at the University is to transform lives by creating opportunity, developing people and shaping the future. At the University of Wolverhampton people are at the heart of all that we do. Those people are our students, our colleagues and our external partners. There are key values and behaviours which drive all that we do; inclusive, ambitious, accountable and resilient. https://www.wlv.ac.uk/strategy-2035/values-and-behaviours/

5. Whistleblowing

The University encourages all workers to report any concerns related to direct activities of the University. This covers any circumstances that may give rise to an enhanced risk of slavery or human trafficking. This is also relevant where anyone may be concerned about the activities of contractors.

This can be done through informal routes; such as through line management, and qualifying disclosures can be made under the University’s Whistleblowing policy (Corporate Policies - University of Wolverhampton).

Whilst Students and apprentice learners are not workers, and not covered by the provisions of the Public Interest Disclosure Act 1998 (PIDA) and the related policy, the University remains committed to ensuring the highest professional standards and urges students and apprentice learners to raise any concerns through the Student Complaints Process and Procedure. https://www.wlv.ac.uk/about-us/governance/legal-information/complaints/; they can also raise issues under the Whistleblowing Policy although these will not be treated as being public disclosures under PIDA.

6. Safeguarding Procedures

Our duties as staff members (within the University community) are regularly communicated to all staff and extend to safeguarding concern for our students, apprentice learners, each other, guests and visitors. This includes protecting the rights of adults to live in safety, free from abuse or neglect; and working together to prevent and stop the risks and experience of adult abuse and neglect - including exploitation.

The University recognises that certain groups - particularly international students, students on unpaid placements, and apprentice learners - may be more vulnerable to exploitation due to immigration status, financial pressures, language barriers, or dependency on sponsorship or accommodation arrangements.

Safeguarding procedures therefore include proactive monitoring and training for staff supervising students on placements (both paid and unpaid), ensuring they can recognise indicators of modern slavery, labour exploitation, or coercion. The University requires placement providers to confirm compliance with relevant labour and safeguarding standards and reserves the right to audit or terminate placements where exploitation is suspected.

We have a clear process in place for reporting any concerns with regard to Safeguarding and Prevent related matters and are committed to working with the relevant authorities or agencies where necessary, in consultation with the University Safeguarding and Prevent Group, which is chaired by the University Secretary as the University Designated Safeguarding Lead.

Any Safeguarding concerns should be directed to the University Safeguarding provision via (safeguarding@wlv.ac.uk) in the first instance. https://www.wlv.ac.uk/about-us/corporate-information/safeguarding/

7. Education Agents

Education Agents that are used by the University for recruiting international students have a specific section on ‘Anti-Slavery’ as part of their agreement. All international student recruitment agents undergo due diligence to ensure they operate in line with the UK Agent Quality Framework, with specific emphasis on transparency of fees, prohibition of recruitment-linked debt, and the safeguarding of students from trafficking or exploitation risks.

Regular agent monitoring includes student feedback and spot-checks to ensure no coercive or misleading recruitment practices occur. Agents found to breach ethical or safeguarding standards will be terminated.

8. Placement Learning and Unpaid Work

The University acknowledges that students undertaking unpaid or voluntary placements, whether in the UK or abroad, may face risks related to exploitation or excessive working conditions.

Placement agreements now include a declaration from the provider confirming compliance with the Modern Slavery Act 2015, the University’s safeguarding policy, and relevant labour protections. Supervisors are trained to identify and escalate concerns relating to coercion, unsafe conditions, or any indicators of modern slavery through the University’s Safeguarding and Prevent Group.

9. Due Diligence Process for Modern Slavery and Human Trafficking

As part of the University’s due diligence processes, formal Contract Management activities include contractor’s compliance and the controls they have in place to assess their own supply chains.

We maintain processes to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains via receipt of modern slavery compliance statements for formal Tenders.

The University will not knowingly support or deal with any business involved in slavery or human trafficking, we have zero tolerance to slavery and human trafficking. If any Contractor/Supplier is suspected to be operating in this manner a review will be held and the organisation potentially removed from any formal contracts.

10. Our Supply Chains

Our supply chains include goods, services and works from a wide range of organisations across several categories. We use reputable contractors and expect them to have adequate monitoring procedures and certifications in place e.g. for clothing, we request all Tenderers to comply with Social Accountability International Standard SA8000 and request evidence on their ethical sourcing activities.

Formal Tender activities request Tenderers to complete the standard Cabinet Office questionnaire in the Central Digital Platform, or local Qualification questions where an ‘Open’ tender is not published. The successful Tenderer is requested to provide copies of, or links to, their Statements and Polices where relevant.

11. Compliance

We continue to review compliance of this statement through use of the existing university Policies which can involve members of the following areas:

• Legal
• Human Resources
• Finance including Procurement
• Student Recruitment and Admissions
• Directorate of Students & Education

The Compliance, Risk and Governance Committee has representation from these areas and has a role in reviewing the statement regularly across the year; this is reflected in the Committee’s Terms of Reference. In addition, there is a University Safeguarding and Prevent Group which consists of officers from some of the areas listed above and reports to the Committee on any relevant safeguarding issues.

12. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, relevant Procurement staff are Chartered Institute of Procurement and Supply (CIPS) qualified, or working towards the qualification, and therefore follow the CIPS Code of Conduct. This is detailed in our Procurement Strategy.

The University provides appropriate training, including annual safeguarding awareness mandatory training, to all University personnel; this is also available to those who may be working on behalf of the University, thus covering temporary staff and critical contractors. 

13. Update and Future Developments

Following a review of the effectiveness of the steps we have taken to ensure there is no slavery or human trafficking in our supply chains, we committed to a number of actions. Below is an update on those actions:

• The Supplier Code of Conduct is available on our Procurement webpages and will be referenced when conducting a formal Tender; a link will also be considered for the Purchase Order to cover spend activity that has not involved Procurement.
• We have developed and implemented a Modern Slavery Policy which is accessible on our Governance webpages.
• Any concerns about potential human trafficking can be raised (anonymously if needed) through the University’s Safeguarding policy using existing safeguarding procedures.
• We Continue to monitor compliance of contractors via Tender submissions and ongoing Contract Management.
• We continue to assess any ongoing specific training needs for staff in respect of the Modern Slavery Act, this will include frontline staff from areas such as international recruitment, placements, student support etc.
• As part of our Governance Effectiveness review, to enhance our decision making, we seek to build an ethical framework which will complement existing policies and procedures to embed the University’s ethical values and principles in all our activities.

Endorsed by:

Chair of the Board of Governors, Angela Spence 

University of Wolverhampton

January 2026

For reference, the University also adheres to:

UKCISA (UK Council for International Student Affairs) safeguarding guidance

Universities UK’s “International Student Safety and Wellbeing” framework

QAA guidance on placement learning and student welfare