Corporate report

SLC's modern slavery statement 2018-19

Published 23 April 2020

1. Modern Slavery policy statement

Student Loans Company Limited (“SLC”) is committed to the highest level of ethical standards and has a zero-tolerance policy towards modern slavery and human trafficking. We are committed to acting ethically and with integrity in all business dealings and to taking steps to ensure that modern slavery and human trafficking do not exist in any part of our business or supply chains, and to continually improving our practices to combat these crimes.

2. Our business

SLC is a Government funded non-profit making organisation set up in 1989 to provide loans and grants to students in universities and colleges in the UK. SLC is a limited company and an Executive Non-Departmental Public Body owned by the Secretary of State for Education, the Scottish Ministers, the Welsh Ministers and the Minister for the Economy, Northern Ireland. SLC plays a central role in supporting the Higher Education (HE) and Further Education (FE) sectors by: making timely and accurate payments of maintenance grants and loans to learners; and ensuring timely and accurate payments of tuition fee loans to HE and FE providers. We also work in partnership with HM Revenue and Customs to collect repayments, as well as collecting repayments directly from some customers. We are located at five sites across the UK in Glasgow, Darlington and Llandudno Junction, and employ roughly 3,500 employees. More information about SLC can be found here.

3. Our supply chain

SLC purchases a range of goods and services with third party suppliers, in excess of £120 million per annum, in line with the legal framework which governs public procurement. We will often use public sector framework agreements to contract with suppliers, such as the Crown Commercial Services framework, or the Scottish Government framework. SLC has a relatively small supplier footprint with c600 suppliers used in the 2018-19 financial year, most of whom we have a long-term relationship with. We have 6 broad categories which cover the bulk of our supply chain:

• business support suppliers;
• property and facilities management suppliers;
• people and professional services suppliers;
• ICT – software suppliers;
• ICT – hardware and telecoms suppliers; and
• ICT - IT services.

4. Due diligence process, risk assessment and prevention

Overall, the nature of SLC’s business means that the risk of modern slavery and human trafficking in our directly managed business activities and the first line of our supply chain is relatively low. We continue to review our operations to identify areas where there could be a risk of modern slavery within our business or within our supply chain and considered what policies and safeguards we have in place to prevent this.

At SLC, our recruitment processes are designed and managed to ensure that all prospective employees are legally entitled to work in the UK. All our employees work within the UK. Via the Baseline Personnel Security Standard process, all employees are required to undertake right to work, referencing and criminal conviction checks to ensure a consistent and compliant approach. We are committed to upholding the highest standard of employment practices. SLC also recognise one of the largest trade unions in the UK, PCS, in respect of its staff. We have been an Investors in People organisation since 2000 and are committed to ensuring all our people processes and practices meet their standards.

We consider that all of these processes and procedures operate together as proportionate safeguards against the risk of modern slavery occurring within our own business. Any concerns raised will be fully investigated and appropriate remedial action taken.

Due to the robust complaint controls SLC has in place, we believe that the risk of modern slavery in our supply chain is relatively low. However, SLC recognises the potential risks inherent in the supply chain of goods and services and is committed to upholding the Chartered Institute of Procurement and Supply Ethical Code of Conduct which requires due diligence to be undertaken on appropriate supplier relationships in relation to forced labour and other human rights abuses. If SLC were to become aware of modern slavery or human trafficking in the business or supply chain of any of its suppliers, we would review our rights to cancel the relevant contract/s and notify the appropriate authorities.

5. Policies relating to modern slavery and human trafficking

In addition to this Statement, SLC has certain policies and procedures in place which contribute to meeting the requirements of the Modern Slavery Act 2015 and preventing slavery and human trafficking in our business and supply chains. All policies are reviewed periodically to ensure they remain current and relevant. Staff policies are easily accessible by all employees and are regularly highlighted and promoted through internal staff communications.

SLC has a Recruitment Policy which promotes a transparent recruitment process which, in particular, ensures that all prospective employees have the right to work in the UK, their identities are verified and each individual is properly vetted. All roles are subject to job evaluation, and rates of pay are set in accordance with a clear and transparent grading structure, with all employees receiving at least minimum wage. Should a member of staff have a concern related to modern slavery, it could be raised either through our Grievance Policy or Whistleblowing Policy. Whilst these policies don’t yet make explicit reference to the Modern Slavery Act 2015, this is something which we intend to address upon the next review of these policies. All staff policies are regularly and robustly enforced by SLC’s People (HR) department.

6. Effective action taken to address modern slavery

During the 2018-19 financial year, we took the following steps to better understand our supply chains and work towards greater transparency and responsibility towards people working within them:

• We included a mandatory requirement in new SLC invitations to tender, where appropriate and proportionate, that potential suppliers must declare that they (and any sub-contractors): (1) are compliant with the Modern Slavery Act 2015; (2) will implement appropriate controls to prevent modern slavery; and (3) must notify SLC immediately if they become aware of any instances of modern slavery within their own business or supply chain;
• We included the right in SLC standard contract terms and conditions to terminate a contract with immediate effect if a supplier is found to be deliberately using or otherwise benefitting from modern slavery, and to oblige any supplier using a sub-contractor, or other third party, practicing modern slavery or benefitting from it, to immediately cancel that sub-contract; and
• Our Commercial Manual was updated to include specific reference to the Modern Slavery Act 2015, with guidance provided to relevant staff on how any concerns should be reported.

7. Further steps

SLC is committed to better understanding our supply chains and working towards greater transparency and responsibility towards people working within them. During 2019-2020, SLC will:

• Ensure that the Modern Slavery Act 2015 is referred to and consideration of the modern slavery risks and steps for prevention are added to relevant SLC policies, including our Whistleblowing Policy.
• Continue to promote staff awareness of the Modern Slavery Act 2015 and consider any training needs for relevant staff in respect of the requirements of the Act.

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken by SLC in the financial year 2018-19 to combat modern slavery.

Paula Sussex, Chief Executive Officer

Student Loans Company Limited

This statement was approved by the Board of SLC on 30 January 2020