KCL Doesn’t Comply with the Modern Slavery Act

King's College London asserts a firm commitment to complying with the Modern Slavery Act 2015 (MSA). This legislation mandates organisations to ensure transparency in their operations and supply chains, thereby combating modern slavery and human trafficking. KCL's official stance is one of zero tolerance toward non-compliance with the MSA. However, a closer examination of the university's practices, investments, and partnerships reveals complexities and challenges in truly adhering to the spirit of the MSA.

Compliance and Transparency Measures

KCL has implemented several measures to address the risks of modern slavery within its supply chains. The university has partnered with Electronics Watch, a human rights monitoring organization, to enhance transparency in its electronics supply chain. Electronics Watch employs a worker-driven monitoring methodology, which is praised for its effectiveness in detecting and eliminating modern slavery. This method involves local civil society organizations that engage directly with workers, ensuring that abuses are reported and addressed.

Furthermore, KCL has procured Crossword Cybersecurity’s Rizikon Assurance Tool, a Supplier Assurance Tool designed to assess and monitor suppliers' compliance with social, ethical, environmental, and governance standards. These steps are indicative of KCL's proactive approach to identifying and mitigating the risks associated with modern slavery.

Despite these efforts, there are significant concerns regarding the effectiveness and thoroughness of KCL's compliance measures. For instance, the Electronics Watch approach, while commendable, raises questions about the transparency of its findings. The initial confidentiality of reports, which are only disclosed to brands and affiliates, including KCL, could delay necessary corrective actions and limit the university's ability to respond swiftly to identified abuses.

Moreover, the reliance on terms such as "reasonable and proportionate" within Electronics Watch’s contractual obligations lacks clear definitions, potentially undermining the enforceability of these obligations. The allowance for summarizing findings from up to two years prior further dilutes the effectiveness of these measures, providing companies with a loophole to potentially sidestep compliance by presenting outdated information.

Investment Practices and Ethical Concerns

KCL's investment portfolio also raises ethical concerns, particularly regarding its indirect support of companies linked to forced labour and human rights abuses.

Notable examples include:

1. BAE Systems: Engaged in arms sales to authoritarian regimes known for forced and child labour.

2. Boeing UK: Tied to the use of forced prison labour in the United States.

3. Caterpillar: Linked to forced labour camps in Xinjiang and lacks third-party verification in its supply chains.

4. Serco: Associated with the use of prison labour and criticized for its handling of modern slavery within its operations.

5. Rolls Royce and Raytheon: Both companies face allegations related to forced labour in their supply chains and unethical practices in their operations.

These investments, although not direct violations of the MSA, contradict KCL's stated commitment to ethical practices and highlight a dissonance between the university's financial activities and its ethical responsibilities.

KCL's engagement with companies operating in Israel and the occupied Palestinian territories further complicates its compliance with the MSA. The security arrangements for Palestinian workers in Israel, the trafficking of women from the occupied territories into Israel, and the exploitation of Palestinian and African Jewish laborers in the West Bank are severe human rights violations. These practices, which are akin to modern slavery, underscore the ethical implications of KCL's investments and partnerships in the region.

King's College London’s efforts to comply with the Modern Slavery Act 2015 are commendable but insufficient. While the university has implemented several mechanisms to monitor and address modern slavery risks, significant gaps remain. KCL's investments in companies linked to human rights abuses, coupled with the limitations of its current monitoring tools, suggest a need for a more robust and transparent approach. It is imperative that KCL not only adheres to the letter of the law but also embraces the spirit of the MSA by ensuring that its financial and operational practices do not contribute to modern slavery in any form.

KCL must take immediate steps to address these concerns, ensuring that its commitment to human rights is reflected in all aspects of its operations, from supply chains to investment decisions. Only then can the university genuinely claim to uphold the principles of the Modern Slavery Act 2015.

Sources

1. King’s College London– Financial Statements 2023. [Link]

2. KCL Modern Slavery Act Transparency Statement. [Link]

3. Rizikon Assurance Supplier Assurance System. [Link]

4. Electronics Watch Briefing Note. [Link]

5. When Workers Lead on Enforcing Labour Standards: A Case Study of Electronics Watch. [Link]

6. Electronics Watch Contract Conditions. [Link]

7. How BAE Systems helped arm almost half the world. [Link]

8. State-Imposed Forced Labour in Turkmenistan: Now Is the Time for Action. [Link]

9. Profiting off of Prison Labor. [Link]

10. Making Slave Labor Fly: Boeing Goes to Prison. [Link]

11. Deconstructing Modern Slavery Statements: A Detailed Analysis of Arcadia Group and Babcock International. [Link]

12. Caterpillar Modern Slavery Compliance Statement. [Link]

13. Caterpillar’s Links to Forced Labor in Xinjiang. [Link]

14. Caterpillar's Public Statements vs. Actions. [Link]

15. Serco and Modern Day Slavery. [Link]

16. Violence Old and New: From Slavery to Serco. [Link]

17. HMI Prisons Report on Tinsley House. [Link]

18. Modern Slavery and Rare Earth Minerals in Rolls Royce’s Supply Chain. [Link]

19. Risks of Forced Labor in Electric Vehicle Supply Chains. [Link]

20. Raytheon’s Dealings with Qatari Defense Contractor. [Link]

21. Raytheon’s Indications of Improper Payments in Middle East. [Link]

22. Raytheon Anti-Corruption Issues. [Link]

23. Carrefour’s Forced Labor Lawsuits. [Link]

24. The Crisis Dividing Israel: Palestinian Workers in the Balance. [Link]

25. Trafficking and Forced Prostitution of Palestinian Women and Girls. [Link]

26. SodaStream's Treatment of Palestinian Workers. [Link]