In common with reporting obligations on issues such as conflict minerals and illegal timber, the anti-slavery provisions are designed to get companies to take more responsibility for their supply chains. Ultimately, such laws could have the effect of extending standards demanded by western consumers and campaign groups to supplier countries.
But while more information on efforts to combat slavery in supply chains is welcome, the impact of the Modern Slavery Act is not entirely predictable.
It is likely to be almost impossible for companies to guarantee that their supply chains are slavery-free. Clothing brands, for example, are cautious about making declarations about their products not containing cotton from Uzbekistan, where forced labour is used. The complex supply chain and mixing of cotton from different sources at spinning mills make it hard to be 100% sure.
So what can companies do to try to attain transparency in their supply chain?
10 steps to achieving transparency
1.Are you an organisation that falls within the “commercial organisation” definition of the Modern Slavery Act?
2.What can you adopt in order for your company to fit within existing strategic objectives?
3.Understand the countries in which your organisation operates – remember that some countries pose a higher risk with regard to slavery incidents than others
4.Who in your company works on supply chain and your company’s operations? Identify the relevant personnel
5.If you have existing policies update these to include slavery and forced and bonded labour wording
6.If you have existing checklist or purchasing policies, then re-review and revise accordingly
7.Look at your supplier codes of conduct and supplier contracts – what do you need to do to include the minimum labour standards?
8.How will you carry out your due diligence on your supply chain? Do you have any due diligence procedures?
9.Ensure that all of your personnel are aware of your anti-trafficking policies and processes
10.Ensure that you have given appropriate training to your personnel and have emphasised the importance of the Modern Slavery Act