As a world-leading research organisation, we ensure that our research is conducted according to appropriate ethical, legal and professional frameworks, obligations and standards. We provide a research environment that is underpinned by a culture of integrity and based on good governance, best practice and support for the development of researchers.
Earlham Institute staff recruitment policies ensure that employees are legally entitled to work in the UK with the necessary and appropriate checks undertaken. Staff undertake mandatory training in equality and diversity to safeguard employees from abuse. The institute also maintains a whistleblowing policy which is clear and easily accessible to staff.
As a registered charity, Earlham Institute has a responsibility to ensure that the funds it receives are properly spent, in accordance with the law, funder requirements and in the public interest. We support the requirements of the Modern Slavery Act 2015 and we are committed to carrying out procurement activities in an environmentally, socially, ethically and economically responsible manner.
Our supply chains fall mainly under five ‘super-categories’, which are:
- Laboratory Consumables and Equipment
- Library Resources
- Professional Services
- ICT Equipment and Services
- Estates Goods and Services
The principal categories deemed as carrying material risks with respect to Modern Slavery are laboratory consumables, ICT equipment and some estates services. A significant amount of our procurement is undertaken through our membership of the London Universities Purchasing Consortium (LUPC), a non-profit professional buying organisation which is part of the UK University Purchasing Consortia. LUPC is a leader in promoting respect for human rights in public supply chains and is committed to supporting the UK Government’s National Action Plan, to implement the UN Guiding Principles on Business and Human Rights. LUPC has focused on these highest risk categories by running pilot due diligence projects in these areas, and by maintaining its affiliation to monitoring organisation Electronics Watch.
In line with Home Office guidance, we aim to make progress over a period of time across a broad range of potential exposures.
During the financial year ended 31 March 2026 we have:
- We have ensured that all staff involved in procurement have completed mandatory training and continued membership of LUPC.
- Taken steps for new suppliers to adhere to the Modern Slavery Act and, if necessary, consolidate this information for future use. Continued to progress in contacting existing suppliers who haven’t provided a Code of Conduct or Modern Slavery Statement to request that this is provided.
- Encouraged the utilisation of suppliers that are either registered with LUPC, have satisfactorily complied with the Supply Chain Code of Conduct, or provided a Modern Slavery Statement.
- Continued reviewing our agreements to incorporate obligations for compliance with the Modern Slavery Act as necessary and implemented due diligence measures to mitigate any potential risks.
- Ensure our shared services provider for FM services completes rights to work checks on the staff it employs.
Risk Analysis
While a significant proportion of our procurement is undertaken through LUPC, which carries inherited supplier due diligence and an affiliation with Electronics Watch, Earlham Institute directly manages several categories of higher risk spend outside these arrangements. Our principal areas of exposure are:
- Laboratory consumables and reagents, where overseas manufacturing and multi-tier packaging and distribution chains make it difficult to trace working conditions beyond the immediate supplier.
- Specialist and bespoke laboratory equipment, often available from a small number of manufacturers, which limits our ability to apply commercial leverage if concerns are identified.
- ICT storage and compute infrastructure, a high-value category with electronics supply chains that have been repeatedly flagged by human rights monitoring bodies, including Electronics Watch.
- Construction and capital works, undertaken on an ad hoc basis for laboratory and estates projects, which can rely on multi-tier subcontracting and agency labour — a combination associated with elevated modern slavery risk in the construction sector more broadly.
As of June 2025, of our 161 active suppliers: 21.7% (35 suppliers, 26.9% of spend by value) are procured through LUPC frameworks, which carry inherited due diligence; 47.8% (77 suppliers, 66.6% of spend by value) hold a Modern Slavery Statement or have signed our Supply Chain Code of Conduct directly; and 30.4% (49 suppliers, 6.5% of spend by value) are on our standard terms and conditions with no Modern Slavery Statement or Code of Conduct in place.
This last group represents our principal residual risk. Although low in overall spend value, the number of suppliers in this category has grown by 14% since June 2024, while the number of suppliers covered by LUPC or by a direct statement or code has fallen (-12.5% and -11.5% respectively). We consider closing this gap — rather than headline spend coverage to be the most meaningful indicator of progress.
Controls and Mitigation
During the financial year ending 31 March 2027 where procurement is performed through us directly rather than LUPC, we will do the following:
- Enhance our strategy in the areas of Purchasing and Facilities by conducting a thorough review of our NBI Supply Chain Code of Conduct. This includes aiming for compliance from new suppliers and incorporating it into our tendering activities.
- Continue to review our current supplier base to ensure that NBI suppliers remain compliant with our established code of conduct. We will challenge suppliers who cannot provide a suitable statement and, if necessary, remove them from our supplier base if they are deemed non-compliant. This will allow us to prioritise ethical suppliers.
- Prioritising direct outreach to the 49 suppliers currently on standard terms and conditions, to obtain a Modern Slavery Statement or signed Code of Conduct or otherwise reassess the relationship.
- Introducing a due diligence check for any purchase over £100,000 made outside a framework agreement, requiring evidence of supplier Modern Slavery compliance, or a completed risk questionnaire before a purchase order is raised.
- Continue to review our key performance indicators to monitor and comprehend any shifts in supplier behaviour that could potentially compromise our established code of conduct as stated in our Modern Slavery statement.
- Ensure that our Modern Slavery training is up to date and, if necessary, to incorporate the latest information and guidance and ensure any new staff are fully trained.
- For construction contracts over £100,000 require the principal to evidence their own labour supply chain due diligence — including how on-site subcontracted and agency labour is recruited before work commences, and build this into our tendering and contract terms.
This statement has been approved the Board and signed on its behalf by the Chair:
Professor Deborah Smith
Trustee Director
14 September 2026
