Slavery and Human Trafficking Statement for the financial year ending 31 July 2023

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 2023. 

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. Over this financial year we have continued to ensure that we have the right policies and processes in place, build internal capability to understand and manage future risks as the business evolves, and maintain sustainable commercial relationships with our business partners and suppliers. 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 two wholly owned trading subsidiaries, UCAS Media Limited and UCAS Consultancy and Insights (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 580 people, in Cheltenham, UK and has an annual turnover of circa £54m. 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, so its commercial activities help it deliver its mission and vision, while 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, achieve and belong. 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 and supporting documents that underpin this are:

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

All these policies have been included in our annual policy compliance exercise which is mandatory for all UCAS staff to complete. The training has been delivered via short online training modules highlighting the key parts of each policy, ensuring that staff know where on our internal SharePoint site to find the policy and who they should speak to if they need assistance. Short knowledge checks have been built into the training modules to reinforce key messages. These training modules will remain available for staff to access as part of our programme to embed ethics across the business internally. These policies are also a mandatory part of our induction process for new employees, who will also have access to the online courses. Further modules will be developed of these introductory modules to provide more in-depth training for those in more senior roles for example, or those who are seen to be in ‘higher risk’ roles, such as directly working with suppliers and industry customers. 

Our Ethics and Compliance system is a purpose-built third-party risk management system which provides a tailored, step by step, electronic process to onboard new customers and revalidate existing customers, so there are consistent assessments about new and existing business partners across the organisation. This includes several automated compliance checks (e.g., FCA register validation / licensed activity / background searching). The system helps UCAS to readily follow up new customer leads, understand who they are, the nature of the business, the scope of opportunity in an efficient, risk based and transparent way. 

Our Customer Framework has been embedded into the workflow checks within the Ethics and Compliance system to ensure that right at the start of the onboarding process, the sector and products/services of a prospective business partner are checked and confirmed as being acceptable. Our Business Partner Code of Conduct has also been set up as another of the workflow steps and makes it a requirement for every new customer onboarding to confirm that they have read and understood our Business Partner Code of Conduct, which re-iterates UCAS’ commitment to  operating ethically, demonstrating integrity, and acting responsibly to its customers and stakeholder and 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.  

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 continuing to conduct 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, and shall comply with the applicable laws and shall implement due diligence procedures to ensure that compliance is maintained. Our Business Partner Code of Conduct is also embedded into our standard Terms and Conditions to further re-affirm our expectations on suppliers to act in accordance with these principles and values. 

In addition, this year, we have extended our independent whistleblowing hotline so that third parties can make reports of any concerns as well as UCAS employees to further enhance our commitment to operating sustainably and ethically. Any concerns raised by third parties will be treated in the same way as those raised by employees.  


Together, our Customer Framework and our Business Partner Code of Conduct assist in ensuring that all business interactions are consistent with the mission and values that uphold UCAS’ reputation. They act as living documents and are reviewed and amended/extended where there is a reasonable business need, with the support and assistance of the UCAS Media Advisory Group to strike the right balance between the need for growth and maintaining UCAS’ reputation and help us shape and maintain our portfolio with the ethos of UCAS’ ethics and integrity.  
This statement was approved by the Board of Directors of UCAS on 7 December 2023.

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

Trudy Norris-Grey


Date: 7 December 2023