Today’s world demands that businesses have a clear and comprehensive approach to identifying and managing risks relating to modern slavery. This focus is coming not only from consumers and legislators, but also investors.
Investors believe that companies that are transparent about human rights issues in their operations and supply chain are more likely to demonstrate better management practices overall. They see the reporting on, and response to, modern slavery risk as an excellent indication of the organisation’s general risk management. Not to mention the competitive advantage that a business can gain by demonstrating a thorough and professional approach to mitigating the possibility of modern slavery in its supply chain.
The following checklist is designed to help your organisation offer a comprehensive and transparent approach to managing human rights risks that will help increase investor confidence whilst meeting your legal obligations.
1. Policies
Investors will be looking for signs that businesses are digging deep into their supply chains, operations and investments to assess and address their modern slavery risks. Having effective policies in place is the first step to demonstrating an appropriate level of transparency and maturity.
Does your business have a policy on slavery and human trafficking?
Is there a procurement policy or supplier code of conduct that should form part of your Modern Slavery Statement?
Does the policy specify minimum labour standards expected of the business and its suppliers? Do these conform with industry standards?
Does your business take into account fair labour and legal costs in order to reduce incentives for using cheaper slave or bonded labour in your supply chain?
Does your business incorporate your anti-slavery and human trafficking policy into its contractual and other business processes?
Which companies are contractually required to comply with this policy − all suppliers or just first-tier suppliers?
If your business discovers a supplier is not complying, what are the consequences?
If cases of modern slavery and forced labour are discovered, what procedures do you have in place to protect the workers from further victimisation or vulnerability?
2. Whistleblowing
Organisations can’t be expected to identify every modern slavery risk from a distance. Instead, ensure transparency through the establishment of channels and processes to allow for concerns to be raised in a safe and secure manner.
Does your business have a whistleblowing policy? If so, do procedures exist to assist reporting? Does your business protect whistleblowers?
3. Management
Your business should have a manager that is directly responsible for ensuring compliance with your slavery and human trafficking policy. They should be immediately identifiable by everyone in the business. Their responsibilities include managing the risk of modern slavery in the business and its supply chains, instigating and overseeing investigations, and ensuring that all basic labour standards are met.
Is this individual suitably resourced?
How does management deal with policy breaches? Does the compliance program identify what steps should be taken in response to a breach?
4. Controlling the risk
Your business should ensure that due diligence is undertaken to identify risk areas and activities, carefully consider what those risks are, and create plans for managing those risks going forward.
Are you deciding when and how risk assessments are to occur and putting action plans in place, should a risk be identified?
Are you considering what areas of the world your supply chain passes through? Have you reviewed any countries with higher risk factors, such as conflicts, weak rule of law, and large migrant populations?
Are you regularly reviewing the plans and policies your factories have in place, and whether they are, if fact, being implemented?
Have you looked at how you choose brand collaborators and how you assess their compliance?
When signing agreements with supply chain partners, are you failing to put in specific slavery and human tracking policies? You could choose to promise that the specifics of the policy will be provided to the partner at a later date, so it doesn’t delay signing of the contract. But you need to ensure that the policy, and any updates, do get communicated. It is your responsibility to make certain your supply chain partners are aware of their obligations.
5. Keeping track of compliance
Investors will be expecting you to have set standards against which you regularly measure your business and its supply chain. Simply putting policies in place is not enough. The issues and locations of modern slavery are fluid and ever changing.
Are you keeping your standards under review?
Have you established a team to test and question these standards on a regular basis?
Have you sought to ensure that your supply chain partners are also auditing their risk?
Are you making your Statement publicly available and open to feedback from the public as well as employees and supply chain partners? Is there a designated way for people to contact your business with concerns?
6. Educating and training your workforce
Addressing modern slavery risk requires participation from all employees. The more educated your workforce is in spotting risks and issues, the better for your compliance requirements – and your investment opportunities.
Have you assessed what training is available and, where necessary, refreshed it?
Are you keeping records of who has undertaken training, and when?
Implementing an action plan.
Reducing the risks of modern slavery and enhancing investor confidence relies heavily on how your Procurement team functions. But it doesn’t stop there. With the impact of supplier behaviour capable of impacting your reputation, it means taking action to ensure your suppliers, and suppliers further down the chain are reducing the risks in turn. We’ve created a whitepaper that will help you implement a comprehensive action plan for all suppliers; Closing the gap on modern slavery: An action plan to help your suppliers – and their suppliers – reduce your modern slavery risk.
You can request your copy here.
