1. Businesses and supply chains
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.
2. Policies
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:
3. Due diligence
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:
4. Mapping risk
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:
Companies can also use different guides to conduct their own risk mapping exercise using tools such as:
5. Training
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.
6. KPIs and effectiveness
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.
Download the full PDF Guidance for businesses
Licensed premises
Licensed premises, such as hotels, adult venues, restaurants and pubs, are at particular risk of exploitation occuring at their premises.
The Modern Slavery Act places a responsibility for organisations to detail what steps they are taking to ensure modern slavery is not happening in their business.