Who is Affected by Modern Slavery?
We all are!
However, every large company faces a higher risk of being involved in the modern slavery supply chain. This may be through their own operations and also through supply chains where manufacturing, sourcing, financing and hiring are outsourced. When unchecked, these risks are even higher when the supply chain is complex.
Companies with a threshold of over £36 million annual turnover in the UK (estimated 12,000 companies) must publicly issue a modern slavery statement annually to comply with the Modern Slavery Act requirements.
This means that retailers and high street brands will have a huge job on their hands to obtain, investigate, verify and validate the information about their operations and supply chain. Disclosing this type of information to the public is not generally issued, it presents a risk to the company, however there is no way for them to escape the requirements the law sets out for them. ETI found that over 70 per cent of companies believe slavery is likely to exist in their supply chain. Read here for more information about their findings.
It is our responsibility to take actions to ensure modern slavery does not take place in our operations or supply chains.
So how can we take responsibility?
The UK government suggests we asses our companies in six key areas:
- Organizational and supply chain structure
- Company policies
- Due diligence processes
- Risk assessments
- Effectiveness of measures in place and training
Tackling Modern Slavery Statements
To be in line with the Modern Slavery Act, companies must write a statement that shows the company monitors and controls their operations and supply chain. It sets out criteria that needs to be met for each statement published, however most statements that have been produced so far still haven’t been the best quality, meaning that they aren’t complying 100% with the law.
Most statements set out vague commitments and descriptions of their policies and procedures. However only a few include descriptions of their risk assessment activities, remedial actions or their monitoring and measuring the effectiveness of their actions.
Due to the need for clarity, ETI (Ethical Trading Initiative) released a framework to help companies write a modern slavery statement.
So, what is it that we need?
We need an outline to follow that is consistent across the board, an easy framework to follow broken down into industry types.
The Modern Slavery Registration freely provides statements that have been approved, however these are not templates.
ETI has announced that they are launching a framework tohelp us confused people and then are planning to produce an online version on their website. However, this shouldn’t be mistaken as a template.
Each statement should be specific to your own organisation, you need to demonstrate your organisation is continuously improving against a set of agreed minimum standards and meet all the criteria set out in the Modern Slavery Act. Thisis why ETI has produced a framework and not a general template, organisations should be compliant to the standard according to the operations and supply chain of their company.
Some great resource to help you are:
- Ethical Trade Modern slavery statements – a framework for evaluation
- Stronger together resources – https://www.stronger2gether.org/resources/
- CORE Coalition – Recommended Content for a Modern Slavery Statement
Guides & Reports
- Beyond Compliance: Effective Reporting Under the Modern Slavery Act
- Modern slavery statements – One year on (report)
- Modern Slavery Reporting: Case Studies of Leading Practice
- Transparency in Supply Chains, etc., A Practical Guide,
- Base Code Guidance: Modern Slavery
- Slavery on the high street
- Forced labour in the UK
- Identifying, managing, mitigating and preventing forced labour and modern slavery
- Corporate approaches to addressing modern slavery in supply chains
- extracted from Business & Human Rights:
Ensure corporate executives prioritise modern slavery as part of the strategic agenda of the company and support all departments implementing relevant policies and strategies.
Collaborate with their peers to investigate modern slavery risks common supply chains through deep-dive research, and share insights to help develop best practice.
Raise awareness among their suppliers of modern slavery risks and require them to conduct due diligence in their operations and supply chains.
Engage with companies on their actions to tackle modern slavery and reward companies that demonstrate due diligence to avoid slavery and provide remedy. More information is available in CORE Coalition’s briefing, Engaging with Companies on Modern Slavery – A Briefing for Investors.
UK Government should:
Improve the monitoring and enforcement mechanisms to ensure companies that are required to report under the Act feel pressure to comply and are penalised if they fail to do so.
Publish a list of the companies required to produce statements under the Act and support open, free, and accessible information regarding company compliance;
Provide clear incentives for corporate action: bids for public contracts should be dependent on companies demonstrating due diligence in their operations and their modern slavery statements.
These videos have been published by Stronger Together, they are very powerful to highlight the extent of modern slavery.
- Tackling Modern Slavery – Stronger Together Introduction
- Stronger Together – Daniel and Weronika’s Story (English)
- Forced labour awareness video for induction and worker training programmes in the construction sector.
- Forced labour in the fruit and wine producing industries in South Africa.
So, what is it that your company is currently doing to help and how did you start?
If you would like to share your company statements or have feedback regarding Tackling Modern Slavery, we would love to hear from you.