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Anti-Slavery and Human Trafficking
Introduction from Chief Executive Peter Phillips
Cambridge University Press is committed to acting ethically and with integrity, and does not tolerate any form of modern slavery or human trafficking. As part of our commitment, we uphold the standards set out in the Modern Slavery Act 2015 by implementing systems and controls to ensure that modern slavery is not taking place anywhere within our organisation, or in any of our supply chains. This statement, made in accordance with section 54 of the Modern Slavery Act 2015, summarises our current approach and sets out the further action we plan to take in the coming year in our business and our supply chains.
The Press plays a leading role in today’s global publishing market place. We have over 50 offices around the globe, and distribute our products to nearly every country in the world. To find out more about what we do and our mission statement, please visit cambridge.org/about-us.
Our Policies on Slavery and Human Trafficking
To further our commitment to combat modern slavery and human trafficking, we have taken the following steps:
- Issued an Anti-Slavery and Human Trafficking Policy and Framework to all Press employees which outlines our zero-tolerance to modern forms of slavery and human trafficking, and reflects our commitment to acting ethically and with integrity in all of our business relationships
- Updated our Code of Ethics to ensure it includes a modern slavery section
- Both the Policy and Framework are monitored and reviewed annually along with our Code of Ethics which is updated and released each year
- Continued to increase our industry-wide engagement on these issues, through being an active participant in the Compliance Committee at the UK Publishers Association, and the Publishers Resolution for Ethical International Manufacturing Standards (PRELIMS), a collaboration of UK and US publishers who have been working together to develop a common process to assess labour and environmental standards
Risk Assessment Processes
An assessment of key risks within our supply chain from a modern slavery and human trafficking perspective indicated that third parties and their activities present a potentially high risk. The activities our third parties undertake which could pose a potential risk are as follows:
- Digital editing and typesetting
- Production of items ancillary to the production of printed materials including, in particular, toys and textiles accompanying certain educational resources
- Production of printed materials
- Supply of electronic devices to the Press
Following a detailed analysis of our global third party community, which is made up of many thousands of suppliers and distributors, we identified that the majority of Press expenditure is with around 2,000 of these third parties. We therefore prioritised the risk assessment of these 2,000 third parties based on their main country of operations (using various global assessments1 of human rights and human trafficking risks by country), expenditure, third party type, as well as internal knowledge of the company in question and its ongoing supply chain.
The results of the risk assessment highlight the following about the risk levels within our supply chain:
High risk: Primarily printers, typesetters and distribution partners (approximately 3 per cent of our global third party base)
Medium risk: In addition to the above, certain IT, supply chain and facilities providers (approximately 12 per cent)
Low risk: A mix of the above, plus other third party types such as digital distributors, marketing suppliers, and internal suppliers, to include legal service companies, accounting firms, IT infrastructure suppliers, etc. (the remaining 85 per cent)
No risk: Authors and freelancers (being individual suppliers)
Due Diligence Processes
The risk assessment processes we have carried out and will continue to carry out informs our approach to due diligence. The steps we take to assess modern slavery risk within our third party due diligence processes are outlined below.
All new third party relationships and any existing third party relationships being reviewed, will be subject to the following:
- Questioning around compliance with international labour law to include specific questions about modern forms of slavery and trafficked labour
- Contractual terms to include modern slavery provisions
- Signing up to our Third Party Code of Conduct thereby requesting they agree to act in accordance with it, including the modern slavery provisions
To raise awareness of modern slavery and human trafficking risks in our supply chain and our business we provide training to our employees. Our anti-trafficked labour training programme combines online training for all employees, with face-to-face training for those in senior or front-line roles.
Measuring Effectiveness – Key Performance Indicators
In order to monitor our effectiveness in preventing modern slavery and human trafficking from taking place in our business and supply chains, we measure our progress against the following key performance indicators (KPIs):
- Keeping our Anti-Slavery and Human Trafficking Policy updated and under review
- Number of employees signed up to or re-signed to our Code of Ethics
- Number of Employees and third parties who have completed training
- Number of risk assessments of third parties carried out
- Amount of Due diligence processes completed
- Number of audit processes completed
- Number of partnerships entered into with relevant organisations such as PRELIMS
This statement is made by Cambridge University Press, a Department of the University of Cambridge, and has been approved by the organisation’s Press Board who will review and update it annually. It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial year from 1 May 2017 to 30 April 2018.
1.The reports that were reviewed included the 2015 US State Department Trafficking in Persons and Workers Rights Report, the Global Slavery Index 2014, the Labour Exploitation Legal Resources and the Corruption Perceptions Index 2014.