Helping you address modern slavery within your business, operations and supply chains.
Businesses are seen as integral to the fight against this horrific crime, which is evidenced in new pieces of legislation, such as the Modern Slavery Act and the California Transparency in Supply Chains Act.
How this applies to your organisation
Section 54 of the Modern Slavery Act 2015 requires all commercial organisations operating in the UK, supplying goods or services and with an annual turnover of over £36 million to publish a statement setting out what steps they are taking to ensure there is no modern slavery in their business and supply chains. This statement must be linked on the company’s homepage, signed by a Director and approved by the Board of Directors.
Even if businesses don’t reach the £36 million threshold under the Modern Slavery Act, most will no doubt find themselves in another company’s supply chain; having sufficient evidence of anti-slavery practices and policies is increasingly becoming part of business tenders. Businesses have been charged with modern slavery crimes and some have faced financial ruin because of subsequent settlements and fines.
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:
- 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.
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:
- 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.
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:
- 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.
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.
It is the responsibility of premises license holders and their managers to make sure that suitable control measures are in place at licensed venues for the protection of children from harm. This is a legal requirement under the Licensing Act 2003.
Police also have powers under Section 116 of the Anti-Social Behaviour, Crime and Policing Act 2014 to serve a notice on a hotel owner, operator or manager requiring guest information in connection with child exploitation.
How exploitation can manifest
- Hotels and restaurants frequently rely on labour providers to employ outsourced staff (like housekeeping and kitchen staff). The multi-tiered recruitment systems and reliance on often low-skilled and migrant labour can mean unscrupulous practices are difficult to detect.
- Licensed premises can become unwitting hosts of perpetrators of sexual exploitation, of both children and adults, who may use the premises as a base for sexual exploitation or for grooming.
- Goods and services purchased by the premises can represent hidden risks in terms of worker welfare within multi-tiered and complex supply chains.
More information on how to mitigate risk of exploitation in your premises:
- Shiva Foundation’s Stop Slavery Blueprint – guidance for all risk areas within hotels, which can be adapted for other licensed premises
- Staff training which can be adapted for hotels or other licensed premises
- Example indicators that staff can be aware of
- Suggested reporting protocols for when an incident is discovered.