Modern Slavery and Human Trafficking Statement

Introduction • Our structure • Our supply chain • Review and approval

Introduction

Sheffield Hallam University is a leading UK institution with approximately 32,000 students and 3,300 staff. As a civic university, we are committed to transforming lives through education, research, and community engagement, ensuring fairness, equality, and environmental responsibility.

We support the UK Government's Action Plan to implement the UN Guiding Principles on Business and Human Rights and align our practices with the Transparency in Supply Chains: A Practical Guide (March 2025), under Section 54 of the Modern Slavery Act 2015. Our approach is risk-based, transparent, and focused on continuous improvement.

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Our structure

We are a provider of Higher Education and research.

The Vice-Chancellor is the University's Chief Executive and is responsible for the executive management of the University. The university’s organisational structure includes three Colleges (Business, Technology and Engineering, Health, Wellbeing and Life Sciences and Social Sciences and Arts), various Business Delivery Groups and Corporate Services. The organisational structure ensures accountability for implementing anti-slavery measures across all functions.

Modern slavery risk management is embedded across the units, with clear lines of accountability and regular reporting to senior leadership. Each group plays a role in identifying, mitigating, and responding to risks within their operational scope.

Our policies, priorities and vision

At the University, our purpose to "transform lives" extends beyond education to include ethical employment practices, responsible procurement, and active community engagement. We recognise modern slavery as a serious violation of human rights and are fully committed to eliminating it from our operations and supply chains.

We expect our external partners to share this commitment. All suppliers, contractors, and collaborators are required to uphold the highest standards of ethical conduct, ensuring that their own operations, and those of their supply chains, are free from child labour, forced labour, modern slavery, and human trafficking. To support this, we are developing policies and continue to strengthen them to reflect our values of sustainability, integrity, and ethical responsibility. We are implementing effective systems and controls to prevent exploitation and ensure transparency throughout our business relationships.

Together, we can foster a culture of accountability and respect, creating partnerships that are not only commercially successful but socially responsible.

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The Sheffield Hallam supply chain

The University’s supply chain encompasses a broad spectrum of goods, services, and works essential to our operations. These include, but are not limited to, areas such as teaching and research, professional services, student recruitment and accommodation, catering, cleaning, security, workwear, IT and audiovisual equipment, laboratory and medical supplies, furniture, stationery, printing, travel, utilities, construction, and facilities maintenance.

Our supplier base is diverse, ranging from individual contractors and small businesses to large multinational corporations. We recognise that the risk of modern slavery and human trafficking is not limited by geography, sector, or supplier size. These abuses can occur at any stage of the supply chain, whether in the UK or abroad, and across all categories of procurement.

As part of our commitment to ethical and responsible sourcing, we continue to assess and monitor our supply chain to identify and mitigate risks related to modern slavery. We expect all suppliers and partners to uphold the highest standards of human rights and labour practices, and to ensure that their own supply chains are free from forced labour, child labour, and human trafficking.

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Due diligence processes for slavery and human trafficking

We apply structured due diligence across all procurement activity, including below-threshold contracts, to assess and manage modern slavery risks. This includes evaluating supplier practices, country-of-origin risks, and sector-specific vulnerabilities. Where risks are identified, we engage suppliers to improve transparency and ethical standards.

University students struggling financially, whether pre-arrival or whilst on campus, can be vulnerable to exploitation which could result in modern slavery. We are aware of this risk and are cautious in our approach to selecting and managing our international recruitment agents and to monitoring the quality of international work experience opportunities, including providing advice to students on how to source work experience and what to expect. We also ensure that students have access to Wellbeing Services as well as a confidential route to reporting issues such as bullying and harassment, sexual harassment and hate crime.

We are members of UKUPC and NEUPC and adopt the Sustain Supply Chain Code of Conduct to ensure ethical standards across procurement.

We promote our expectations through:

Supply chain management by identifying and managing risks across our supply chains, including labour sourcing.
Collaboration with international partners and NGOs to uphold human rights.
Policy development, reinforcing our stance through internal policies and research.
Engaging with policymakers to drive coordinated action.
Student Engagement by supporting student-led initiatives to combat unethical practices.
Case studies by sharing outcomes to demonstrate the impact of our actions.

We align our practices with the ISO 14001:2015 environmental management system and the Ethical Trading Initiative’s Base Code. Our Responsible Procurement Policy, published on our website, reinforces our adherence to Section 54 of the Modern Slavery Act and supports interactive supplier engagement.

Our policies and due diligence processes include:

Supplier screening, ensuring our suppliers have in place suitable anti-slavery and human trafficking policies and processes and to support our commitment to ethical and sustainable business practices.
Identification of risk and corrective action planning through remediation plans.
Conducting annual reviews and escalating persistent issues. Embedding due diligence into procurement, partnerships, and investment decisions.

We enforce ethical standards through:

UKUPC Sustain Code of Conduct: Prohibiting forced, involuntary, or underage labour.
NetPositive Futures Portal: encourage suppliers to report on awareness of modern slavey, ethical trading, economic impact and community impact through the use of the Supplier Engagement Tool.
NEUPC Membership: Providing access to responsible procurement frameworks and monitoring tools that support ethical sourcing and social value.
External Frameworks: We also utilise a range of external public sector procurement frameworks, including those from Crown Commercial Services, which embed ethical trading principles, modern slavery compliance, and social value requirements.
TUCO Audits: Ensure suppliers meet food safety standards, are transparent about their supply chains and adhere to social, economic, and environmental considerations, providing assurance to TUCO's members and clients.

Training

Integral to Sheffield Hallam University's commitment to Equality, Diversity and Inclusion is a desire to share its learning and on-line training. International partners and vested suppliers will be provided with opportunities to access relevant learning resources.

Internally, officers committing high volume/value transactions with suppliers are now required to access the Government Commercial College, tackling modern slavery in supply chains case study to embed their understanding of the indicators of modern slavery and how to mitigate risks. Officers with duties to tender opportunities with the supply market are responsible for ensuring that documentation reflects our commitment to the Modern Slavery Act 2015.

Teams and partners with responsibility for our overseas activities are aware of the duties under the Modern Slavery Act relating to business overseas and receive training from the University to ensure their understanding is refreshed and embedded.

Sheffield Hallam University’s effectiveness at combating slavery and human trafficking for the future

Teaching and Research

Our approach provides a justice-centred perspective that seeks to address the root causes of exploitation and harm. Modern slavery is integrated into our curricula and research:

Undergraduate Modules: Social Justice in Action, The Practice of Law and Policing, Contemporary Criminological Practice, Crime, Harm, and Social Justice, 21st Century Security Threats.
Postgraduate Modules: Contemporary International Issues, Professional Practice Experience (includes equity, diversity, and inclusion).
Research Themes: Capitalism, structural violence, racial and economic inequality, global security.

Research collaboration

In 2024/25, we collaborated with South Yorkshire Police (SYP) on their Race Action Plan. This partnership informs our teaching and exemplifies how universities and law enforcement can address modern slavery and systemic injustices.

This plan focuses on:

Data Analysis: Examining systemic disparities in policing.
Training Evaluation: Assessing inclusion and fairness reforms.
Community Engagement: Strengthening support for underrepresented staff.

Investments

Our Ethical Investment Policy reflects the values and objectives of the University and its stakeholders. The University will consider the ethical standards and attitudes towards the environment of the counterparties, companies or other organisations in which it invests when making investment decisions. Our Ethical Investment Policy is intended to cover investment in the form of cash deposits, treasury bills, equities, bonds and property. It also extends to investments in university spin-out companies and other related parties.
In making decisions on counterparties, companies and other organisations in which to invest, the University will strive to positively invest in organisations whose activities are, on ethical grounds, consistent with the educational and/or research objectives of the University, even where this may reduce returns.
The University does not currently invest directly in any organisation and does not expect this position to change in the foreseeable future. Even if the position were to change, the University would not consider investments that are principally involved with, or contribute to violation of human rights or labour standards and believes that it could adopt this position without a risk of significant financial detriment.
We will continue to strengthen oversight of modern slavery risks in our investment arrangements. While we do not directly manage pension scheme assets, we engage with fund managers to ensure responsible investment practices.

Measuring effectiveness

We utilise the NetPositive Futures portal to assess supplier engagement with ethical trading and social value. While the portal supports multiple dimensions of responsible procurement, we are working to expand our metrics to include additional indicators such as supplier transparency, remediation outcomes, and social impact reporting. We currently track progress across the following key areas:

Completion of modern slavery training by procurement staff
Supplier assessments in high-risk categories
Issuance and monitoring of corrective action plans

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Review and Approval

The Modern Slavery and Human Trafficking Statement will be reviewed annually.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Sheffield Hallam University’s modern slavery and human trafficking statement for the financial year ending 31 July 2025.

This statement was approved by the Board of Governors of Sheffield Hallam University at its meeting on 19 November 2025