Businesses

This section should:

• highlight where the company operates
• what type of structure the business has
• what subsidiaries it has, if any
• include the number of employees and type (i.e. seasonal, contract, full time).
• give an overview of the supply chain, looking at which countries the company’s goods are sourced from.

This section should include policies demonstrating a company’s commitment to the issue and how coordinated their approach is.

Policies can take the form of a single, but  comprehensive, “anti-slavery” policy or can be split into multiple policies covering key known risk areas, such as supplier codes of conduct, recruitment, procurement, child labour and whistle-blowing policies.

It is also important to have some information on how any mechanisms detailed in the policies are enforced, as well as the process for policy development.

Where to get more information:

• Shiva Foundation’s Stop Slavery Blueprint has template policies on recruitment, employee rights, and a supplier code of conduct
• The Walk Free Foundation sample Code of Conduct
• Stronger Together has various template policies, covering ethical trading, forced labour, and remedy.

This section should cover what processes are in place to ensure modern slavery isn’t taking place within the business or supply chains.

While having a policy in place is a good starting point, how can you ensure that the policies are being upheld internally and by suppliers?

Do your processes include auditing or training of suppliers, for example?

What are your processes if modern slavery is found?

It is recommended that initially the company would work with the supplier to resolve the issue, instead of simply terminating the relationship.

Where to get more information:

• The Stop Slavery Hotel Industry Network has created a Framework for Working with Suppliers that details how to map risk and also engage suppliers in your work to address modern slavery
• Recruitment is one of the areas that presents the biggest risk at any level within the supply chain. Verite’s Fair Hiring Toolkit offers advice on improving policies, raising awareness, strengthening assessments and social audits, etc.
• Stronger Together is one of the UK’s leading organisations in this area, building the capacity of businesses and their suppliers with training, templates and guidance. See their Toolkit for UK Employers and Labour Providers and their guidance on Conducting Supplier Visits.
• The Walk Free Foundation has put together guidance on Questions to Ask Employees During a Social Audit.
• BRE have an Ethical Labour Sourcing Self-Assessment which can help any company see how they are doing with their labour sourcing processes in terms of addressing modern slavery. The basic assessment is free and companies can ask their suppliers to do their own self- assessments to understand their practices.

Companies should conduct an assessment of their risk factors relating to modern slavery within their business and particularly within their supply chain.

This process can involve identifying hotspot industries or source countries and then conducting a deep dive analysis into some of the high risk areas.

This section can also include information about social auditing and risk assessments with action plans on how to assess and address risk, as well as develop broader efforts to eliminate modern slavery.

Where to get more information:

• The Social Responsibility Alliance has created a free, open-source data collection template to help organisations map their risk within their supply chains
• Different organisations, like Stop the Traffik and Hope for Justice will help businesses with their risk mapping at a fee
• Verisk Maplecroft helps businesses with their risk mapping at a fee, and has a Modern Slavery Index
• Sourcemap can also help with mapping risk

Companies can also use different guides to conduct their own risk mapping exercise using tools such as:

• The US Department of Labor’s List of Goods Produced by Child Labor or Forced Labor
• The Responsible Sourcing Tool
• The Walk Free Foundation’s Global Slavery Index
• The US State Department’s Trafficking in Persons Report.

Training is key to ensuring policies are correctly implemented and for raising general awareness of modern slavery.

Training builds the capacity of staff and suppliers in raising awareness about the issue and providing information on how to spot and respond to incidents. Training should be targeted based on role to have the greatest effect.

Where to get more information:

• Stronger Together is a leading training provider, particularly for in-class training. There is a fee.
• Organisations such as Unseen and Stop the Traffik will deliver training for businesses. There is a fee for this service.
• There is also online training from various providers which can be adapted for different industries. There is a fee for this service.

Key Performance Indicators (KPIs) are important for driving performance.

The current KPIs companies may use (i.e. cheapest product or short “turn-around” speeds) can unintentionally create environments where modern slavery becomes a risk.

Additionally, how does an organisation know that any of its anti-slavery efforts are having an impact? Adding modern slavery related KPIs to a company’s performance can help ensure progress.