Slavery and Human Trafficking Statement for the financial year ending 31 July 2021

Introduction from the Chair

UCAS is an independent charity that provides applications and admissions services, across a range of subject areas and modes of study, for UK further and higher education providers. 

This is our Modern Slavery statement, published pursuant to Section 54(1), Part 6 of the Modern Slavery Act 2015, for the financial year ended 31 July 2021. 

We are committed to upholding human rights, including ensuring no-one in our direct operations or extended supply chain or customer base is subjected to modern slavery and human trafficking. Our focus over this financial year has been to continue developing the right policies, processes and internal capability to understand and manage future risks as the business evolves, including a focus this year on the business’ expansion into recruiting international students to UK higher education. Our modern slavery approach over the next financial year will seek to further embed and develop our ethical values internally and externally. 

Our business

UCAS is the parent company of three wholly owned trading subsidiaries, UCAS Media Limited, UCAS Consultancy and Insights and UCAS International Limited (the UCAS Group). These commercial subsidiaries provide a variety of services to further and higher education providers and commercial clients wishing to reach applicants. 

The UCAS Group has its head office, employing approximately 450 people, in Cheltenham, UK and has an annual turnover of circa £50m. Income is generated from profit from the wholly-owned commercial subsidiaries, all of which is gift aided back into the charity. The charity also generates income through the application fees paid by individuals, and a fee paid by universities and colleges for students placed. UCAS does not receive any direct financial support from the government, so its commercial activities help it deliver its charitable objectives, whilst keeping costs down for students and education providers.

Our supply chains

Our supply chain network is largely service driven to benefit our applicants and higher education providers. The services provided by our suppliers include managed IT services, overflow outsourced call centre activity, venue hire, agency labour and contractors, as well as support supply chains incorporating IT equipment, facilities management, cleaning, catering, security, office furniture etc. 

Our commercial customers

Our commercial customer base spans a multitude of sectors who want to reach the student market, these include education providers, retailers, financial institutions, accommodation providers and prospective employers.

Our policies and processes


UCAS is committed to providing an environment where employees can flourish, perform, and achieve. We have a variety of supporting documentation to guide employees on how to work in an honest and ethical manner, along with providing appropriate channels to give the confidence to report any suspected unethical conduct in UCAS, by operating an independent whistle-blowing helpline.

The policies that underpin this are:

  • Code of Conduct (UCAS employees)
  • Business Partner Code of Conduct
  • Equality and Inclusion policy
  • Whistleblowing Policy

In the last year we have reviewed our policies and introduced the Business Partner Code of Conduct which sets out the values and principles that underpin all our work, how we chose our business partners with great care, ensuring they are the most competent, ethical and reliable. It also reinforces that we oppose illegal or inhumane labour practices, including the use of forced or child labour. We oppose harsh or inhumane treatment of workers and expect our business partners to ensure that there is no slavery or human trafficking in their business or supply chains. All our business partners are expected to act in accordance with these principles and values.

Supply chain

We continue to be committed to ensuring that the risk of modern slavery and human trafficking occurring within our supply chains, or any part of our business, is kept to an absolute minimum. 

Our procurement policies and processes reflect our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective and proportionate safeguards and controls.  

Today we have our Procurement Policy, an internal policy used to support procurement activities. Also, potential suppliers, (for the majority of contracts over a specified threshold), are required to complete a bidder questionnaire providing confirmation that they have a programme to assure that modern slavery does not exist in either their operations or those of their supply chains and also that all relevant employees are trained to understand what slavery and human trafficking are and how to mitigate the risk of them. We are also introducing periodic audits of our core suppliers who offer their services overseas to satisfy ourselves that the way in which they deliver their services to us meet with our principles and values. 

In addition, our standard Terms and Conditions for the supply of goods and services attached to purchase orders stipulate that suppliers and their supply chains (whether involved in supplying the service or not) must not have been convicted of, or investigated for, any offence involving slavery or human trafficking, shall comply with the applicable laws and shall implement due diligence procedures to ensure that compliance is maintained. 


Our Customer Framework demonstrates our commitment to operating ethically, with integrity and acting responsibly to our customers and wider stakeholders. The UCAS Media Advisory Group continues to assist in providing insight and understanding into the impact of any commercial services on students, applicants, and businesses, and help us shape our portfolio with the ethos of UCAS’ ethics and integrity.

Training and awareness raising

In the last year, all employees have been required to confirm they have read and understood our core compliance policies. Specific anti-slavery and human trafficking training for all relevant UCAS staff has also been completed to better enable screening processes and the identification of risk.

This statement was approved by the Board of Directors of UCAS on 9 December 2021.

Signed for and on behalf of the Board of Directors of UCAS Group by

Trudy Norris-Grey


Date:  9 December 2021