By Ieva Vilimaviciute, Marketing Communications Coordinator at Sedex
The recent UK Modern Slavery Act has been an important catalyst in raising awareness of slavery within businesses worldwide and improving due diligence. With many companies finding the issue on their agenda for the first time, there is a lot of work to get policies and reporting in place, as well as identifying risks in different geographies, product and business relationship types. To help these companies and raise awareness of the issue more widely, we convened an expert panel at the Sedex Conference 2016. Kevin Hyland, the UK’s first Independent Anti-Slavery Commissioner; Colleen Theron, Director at CLT envirolaw; James Swenson, Head of Operations and Delivery at Thomson Reuters; and Marianne Voss, Stakeholder Relations Manager at Sedex, shared how companies can best address the issues of slavery within their own supply chains. Here are their top five tips:
1. Have a company policy and a commitment to tackling modern slavery
James Swenson said that companies are often challenged by time, resources and expertise, and lack commitment from the Board level. He urged businesses to have a company policy on tackling modern slavery in place. Colleen Theron suggested having an internal champion, ideally someone at the Board level who has some influence in decision making: “If you look at any change that takes place in organisation, it tends to be because someone is championing it and they believe that it is necessary for changes to be implemented,” she said.
2. Understand your supply chain and assess risks
The panellists agreed that it is crucial to understand what your supply chain looks like and how exposed you are. They suggested doing a kind of internal clean up to understand how your supply chain works, what the layers are within it and what your suppliers are dealing with. Start with a risk assessment to understand where the risks lie. Having a good system in place to identify risk issues helps to focus resources in the areas that pose the greatest threat: “You can apply a level of due diligence proportionate to that risk, so that you are spending more of your resources looking at your higher risk suppliers as opposed to the lower ones,” said James Swenson.
3. Build on existing practices
Many companies are already doing something to address the modern slavery issues and the panel suggested to further build on existing corporate practices. “Many organisations already have some form of third party risk management in place, and a lot of companies have started incorporating some other regulatory drivers into that process,” said James Swenson. Colleen Theron agreed that “it is not practical to start something completely new that is not aligned to the way you are already doing things, for example if you already have a well-developed health & safety system, you can further build on it and expand it to incorporate the Modern Slavery Act.”
According to Commissioner Hyland, identifying potential high risks will be much easier once you start to understand the issue, and look at it in a very rational balanced way. Companies should start with a piece by piece approach, because if you try and do everything in the first report, you will do nothing, so look just at that very high risk first of all.
4. Partner and collaborate
It is not sufficient to do due diligence just when on-boarding suppliers – you need to ensure that there is a good system of monitoring afterwards, as well as ongoing training and education available for suppliers, said James Swenson.
Modern slavery is not an issue that one can tackle alone and collaboration – among companies, suppliers and NGOs – is essential in bringing out worker voice and building relationships with those on the ground, said Marianne Voss. “Third-party audits help to identify the most common practices that often lead to other types of warnings, but it is also important to explore new tools, such as worker surveys, partnerships with NGOs that have trust and understanding of communities, migration flows, and other tools that are looking at the recruitment process,” said Voss.
Colleen Theron suggested using “a mix of measures to get to the bottom of issues – train your auditors to look for things in a different way, combine internal spot checks and third party audits to getter a better glimpse of what the real concerns are.”
5. Align your CSR, policy and advocacy commitments
Colleen Theron suggested companies look at modern slavery reporting as an opportunity to create more resilient supply chains. According to Commissioner Hyland, the requirement to produce a public statement on modern slavery empowers the public, consumers and investors to start to scrutinise company practices. The desire for greater knowledge and transparency will put pressure on businesses to actively tackle slavery. He emphasised that the reporting shouldn’t be treated as a tick-box exercise but as an actual commitment to be an ethical business: “Once companies get this thinking in their DNA and start looking for solutions, then we will see standards improving and companies in the UK will seek to be the benchmark that others want to follow.”
All the footage from the Sedex Conference is now available on the Sedex YouTube page. You can watch the full session on modern slavery below:
Watch our interview with James Swenson, Head of Operations and Delivery at Thomson Reuters:
Watch our interview with Kevin Hyland OBE, UK Independent Anti-Slavery Commissioner: