Almost two centuries since slavery was abolished across the British Empire, slavery has remained an issue. Although slavery has now been abolished globally, it continues to be practiced in many forms and presents a challenge to supply chain management.
The term ‘Modern Slavery’ itself encompasses slavery, servitude, human trafficking and forced or compulsory labour. The Global Slavery Index estimates that nearly 45.8 million people in 167 countries are in some form of modern slavery, this rises further when statistics relating to human trafficking are included. However, it is widely believed that these statistics underestimate the true scale of the problem.
In October 2015, the UK government introduced the Modern Slavery Act to assist in tackling this. The Act includes a transparency in supply chain provision whereby businesses with an annual turnover of £36m or more must produce a statement each year setting out the steps they have taken in the last 12 months to address instances of modern slavery in their supply chain. A link to the statement must be publicly visible on the business’ homepage and be signed by an appropriate senior person in the business.
Interestingly, a recent review by the Business & Human Rights Resource Centre of 75 company statements found that only 22 met the minimum legal requirements such as a director signatory and a link to the statement on their website’s homepage. Of those that met the minimum requirements only 9 reported on all 6 criteria suggested by the Act. However, this is likely indicative of the stage many companies are at in addressing risks from Modern Slavery.
This is the first year in which companies are publishing statements, and the government acknowledges that it is not a level playing field for all companies. Many companies had already left the starting block with sufficient policies and checks in place to meet the requirements of the Act. However, for many others their first statements show they are starting to act on the issue and the steps they plan to put in place to address supply chain risks.
To comply with the Act, we recommend the following six steps are taken:
- Scope your supply chain and assess key areas for risk
- Establish policies to address modern slavery
- Embed Modern Slavery within existing due diligence processes
- Engage and seek assurances from service providers and/or contractors
- Audit responses
- Publish a Transparency in Supply Chain Statement each year
We are already helping some of our clients with the transparency in supply chain component of the Modern Slavery Act.
If you have any questions, please don’t hesitate to get in touch.
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