Cambridge University Press & Assessment 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. We do this by implementing systems and controls to make sure that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.
For the financial period from 1 May 2020 to 31 July 2021, we have made two statements about modern slavery. The statement below relates to our publishing activities; a separate statement which relates to our assessment activities can be found here
This, our sixth modern slavery statement, is made in accordance with section 54 of the Modern Slavery Act 2015, for the financial period from 1 May 2020 to 31 July 2021.
Cambridge University Press dates from 1534 and is part of the University of Cambridge. Our mission is to unlock people’s potential with the best learning and research solutions. Playing a leading role in today’s global marketplace, the organisation has over 50 offices across the globe. We employ over 3000 people and publish over 50 000 titles by authors from over 100 countries, bringing thousands of subjects and millions of ideas to the world.
Our publishing covers a huge range of subjects with professional books, textbooks, monographs, reference works, English-language teaching publications, software and electronic publishing. Across the whole of our publishing, from starter-level English-language teaching materials for learners worldwide, through curriculum-oriented textbooks and e-resources, to the most specialised academic research outputs, we maintain and extend our age-old reputation for high quality and technological innovation to meet the needs of our customers, authors and readers across the globe. To find out more about what we do and our mission statement, please visit cambridge.org/about-us.
We have a number of policies in place to further our commitment to combat modern slavery and human trafficking. These include:
Our Anti-Slavery and Human Trafficking Policy, which outlines our zero tolerance of all modern forms of slavery and human trafficking. It also reflects our commitment to acting ethically and with integrity in all our organisational relationships.
Our Code of Ethics, which is updated annually, and provides guidance on the standards of behaviour which all our staff must follow. The Code of Ethics reflects the Press’s commitment to implement systems and controls that make sure modern slavery is not taking place anywhere within our organisation or in any of our supply chains. It also states our requirement for relevant third parties to hold themselves and their own relevant suppliers to the same high standards. Press employees are required to certify annually that they have read and understood the Code of Ethics.
Our Third Party Code of Conduct outlines the minimum standard of behaviour we expect from all our third parties (including agents, contractors, distributors, joint venture partners and suppliers). It is provided to all our third parties before we conduct business with them and strictly prohibits the use of modern slavery and human trafficking. It reconfirms our Code of Ethics requirement for relevant third parties to hold themselves and their own relevant suppliers to the same high standards.
Our Global Concerns at Work Policy outlines our commitment to making it possible for employees with serious concerns about any aspect of their work, the conduct of others or the running of our organisation to report such concerns in confidence and with confidence. It includes specific reference to concerns relating to modern slavery and human trafficking.
Our Speak Up portal builds further on the commitment contained within the Global Concerns at Work Policy. It provides not only our employees, but our authors, customers and other third parties with a clear procedure for addressing any concerns, including those relating to modern slavery and human trafficking.
Our Global Procurement Policy is designed to work with our supply partners and their extended supply chains to minimise negative impacts from trading activities on the environment and local communities. To further the commitments made within the Global Procurement Policy, we have signed up to the most widely recognised industry standards for labour conditions, environmental impact and chemical safety. We also recognise the importance of the United Nations (UN) Universal Declaration of Human Rights and UN Guiding Principles on Business and Human Rights.
Our supply chain
Our product supply chains are extensive and global, with suppliers in over 80 countries. We currently operate 14 warehouses worldwide, which are managed either directly by the Press or by third party logistics providers. The principal activities included in our supply chain are as follows:
- procurement of goods and services related to production of printed materials
- procurement of goods and services not related to production of printed materials
- production of items ancillary to the production of printed materials including, in particular, toys and textiles accompanying certain educational resources
- production of digital materials and platforms
- production of printed materials
Assessment of modern slavery risk within our supply chain
Following review of the principal activities included in our supply chain, we have determined that there are six main activities our third parties undertake which could pose a potential risk from a modern slavery and human trafficking perspective:
- digital editing and typesetting
- production of items ancillary to the production of printed materials (toys and textiles)
- production of printed materials
- supply of electronic devices to the Press
In 2016 we completed 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 2000 of these third parties. First, we prioritised the risk assessment of these 2000 third parties, taking into account our annual expenditure with them, their country risk and the product/service risk, as well as internal knowledge of the company in question and its ongoing supply chain. The results of this risk assessment highlighted the following about the risk levels within our supply chain:
High risk: 3 per cent of our supply chain. Primarily printers, typesetters and distribution partners
Medium risk: 12 per cent of our supply chain. In addition to the above, certain IT, supply chain and facilities providers
Low risk: 85 per cent of our supply chain. 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.
No risk: Authors and freelancers (being individual suppliers)
Due diligence processes
Having established where our risk lies, it is important that we conduct due diligence within our supply chain. This is to understand whether there is evidence of modern slavery and human trafficking, and whether there are sufficient controls in place to prevent them. The steps we currently take to assess modern slavery risk are completed as part of our third party due diligence process. All new third party relationships, and any existing third party relationships being reviewed, are subject to the following:
- questioning around compliance with international labour law, including specific questions about modern forms of slavery and trafficked labour to help us understand:
- the processes our third parties have in place to make sure modern slavery and human trafficking do not exist either within their own operations or in their supply chain
- whether they have training programmes in place to make sure their employees are trained to understand ethical concerns and risks in relation to modern slavery and human trafficking
- whether they have discovered instances of modern slavery or human trafficking within their own organisation or their supply chain and, if so, what steps they have taken to make sure the concerns were addressed
- contractual terms to include anti-modern-slavery provisions
- signing up to our Third Party Code of Conduct, thereby agreeing to act in accordance with it, including the modern slavery provisions
As an active participant in the Book Chain Project (BCP), a collaborative effort in the publishing industry to promote a responsible supply chain, we have access to extra information that can be used in our due diligence review. The BCP consists of three modules: Forest Sourcing, Chemicals and Materials, and Labour and Environment. The Labour and Environment module allows us to make sure that our suppliers who have signed up meet recognised standards for labour and environmental practice. Engaging with the BCP allows suppliers to share their audit findings with multiple publishers easily. We regularly monitor information uploaded into the Labour and Environment database to make sure any new information is reviewed and acted upon where necessary. In 2021, we also became a member of Sedex. Sedex is a membership organisation that provides an online platform for businesses to manage and improve working conditions within global supply chains. By using the platform, we have further enhanced our ability to source responsibly by effectively mapping our supply chain and gaining access to ethical and social performance metrics that guide our decision making.
To raise awareness of modern slavery and human trafficking risks in our supply chain and our organisation 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 such as procurement specialists and members of staff within Operations and Supply Chain. Our online training course helps to make sure that all employees are aware of our regulatory obligations. It also makes sure we are able to identify any issues around modern slavery and human trafficking and raise them appropriately so that any concerns can be addressed.
All new Press employees are required to complete the online anti-trafficked-labour training course within one month of starting work, as part of their onboarding process. This process also includes annually certifying that they agree to abide by the Code of Ethics, and provides employees with information about how they can ask questions and raise any concerns.
Measuring effectiveness – key performance indicators
The Press has committed to review its Anti-Slavery and Human Trafficking Policy annually – more frequently if circumstances require. To help measure compliance, the effectiveness of the policy and, through it, our progress in preventing modern slavery and human trafficking from taking place in our organisation and supply chains, we use a number of key performance indicators to monitor the numbers of:
- employees signed up to or re-signed to our Code of Ethics
- employees and third parties who have completed training
- risk assessments of third parties carried out
- due diligence processes completed
- audit processes completed
- partnerships entered into with relevant organisations such as BCP and Sedex
These were first established in our 2015/2016 and we consider whether they are still appropriate as part of our annual review of the Anti-Slavery and Human Trafficking Policy.
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. It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 and covers the financial period from 1 May 2020 to 31 July 2021.