Modern slavery is a human rights issue that includes various forms of exploitation and coercive practices that deprive individuals of their freedom, rights, and dignity. It encompasses situations where individuals are forced or coerced into labor, servitude, or human trafficking against their will.
The demand for a variety of quality goods and services at a low price from consumers, businesses, and governments around the world means that there are bad actors who perpetrate forms of modern slavery to cater to the demand.
Modern slavery can take different forms, including:
Forced labor: Individuals are compelled to work against their will under threat of penalty.
Child labor: Children are exploited for work, often in hazardous conditions.
Human trafficking: People are moved or transported against their will for the purpose of exploitation.
Debt bondage: People are forced to work to pay off a debt, often under exploitative terms.
Forced marriage: Individuals are forced to marry against their will.
Different forms of modern slavery can appear in a company’s operations and supply chains. There's a common misconception that a company must directly perpetrate modern slavery for the topic to be relevant to the organisation, but vulnerabilities in business policies can indirectly allow for modern slavery to occur through supply chain partners.
Bad actors who perpetrate modern slavery using various mechanisms such as recruitment practices, wages, worker housing, and worker identity documents, can attach themselves to a business directly, or indirectly through supply chain partners at any point along the supply chain.
Lack of awareness and understanding.
Cost and complexity of assessing modern slavery risks.
Supplier collaboration challenges.
Supply chain complexity.
Varying reporting, legal and regulatory requirements.
All businesses, including yours, have an important role to play in the identification and prevention of modern slavery. Governments around the world have taken steps in recent years to introduce legislation that requires businesses to assess and report on modern slavery risks to create supply chain transparency. Businesses can assess, address, and report on their modern slavery risks to create more supply chain transparency and make it harder for bad actors to operate.
Businesses need to collect risk data to create supplier profiles and aggregate reports to understand modern slavery risks. This includes inherent risks in your operations and supply chains (geography, sectors, goods/services), as well as information on policies and practices of your suppliers. The data needs to be kept updated, transformed into actionable insights, and made available to internal stakeholders, and any governments that require your company to provide modern slavery reporting.
The best solution is a preventative solution.
Businesses should focus on regularly assessing suppliers for modern slavery risks and implementing policies and procedures to mitigate modern slavery risks. If your business implements policies to prevent your operations and direct suppliers from engaging in particular behaviours, you can require that your suppliers agree to, and have the same policies in place for their suppliers. This is the most effective way to fortify your business against bad actors who try to engage your suppliers with their products and services at some point along the supply chain.
The best position for a business to take on the topic of modern slavery risk assessment, is a position of curiosity and collaboration; to find out what the facts might be, and work with suppliers to reduce any identified risks.
Supplier self-assessment capabilities.
Reporting capabilities.
Action plan / risk reduction capabilities.
Policies and preventative measures.
Secure data storage.
A collaborative approach is crucial to reduce modern slavery risks. Businesses should work collaboratively with suppliers to reduce the risk of modern slavery in their supply chain, otherwise, tension will build as every business tries to police each other.
Businesses need to implement modern slavery policies, and influence the policies of their direct suppliers. Through contractual terms and flow down clauses, it is also possible to influence policy further down the supply chain with Tier 2 suppliers and beyond - even when direct contact is not possible. It begins with a single business and has a waterfall effect.
Businesses need to engage suppliers to collect first-hand data about modern slavery risks, processes, procedures, and policies. By using first-hand data, companies can produce more informative and accurate reports about their operations and supply chains.
First-hand data is essential for businesses to understand how they can specifically work with each supplier to reduce modern slavery risks. The data gathered through an SAQ should be used to create a supplier risk profile to look at modern slavery risks, and should be used to generate aggregated supply chain insight reports.
Using a recognised, objective, modern slavery risk assessment framework with data gathered directly from suppliers allows companies to move beyond theoretical models and publicly available data to gain practical, actionable insights.
It is not enough to say that a business has assessed its suppliers for risks. With increased pressures and scrutiny from governments, shareholders, and consumers, businesses now need to demonstrate the actions that they are taking post-assessment to reduce risks, and ensure protection from modern slavery over time. Continuous improvement towards risk reduction is easy when using a collaborative approach with your suppliers.
Onsite audits are an important method to identify modern slavery risks. However, they are costly and time consuming, so it is important for a business to take a more practical approach and conduct risk identification at a broad level first. Businesses should work with suppliers in a pre-audit process to collect the initial data for as many suppliers as possible to broadly understand their modern slavery risks before committing to an audit for specific suppliers.