Why would I worry about modern slavery? I am not enslaving anyone to do any work for me.”

The slavery problem has nothing to do with me or my company. I am not forcing anyone to work on my construction site.” You must have heard that before.

But slavery is not a thing of the past, and unfortunately, the problem is more ingrained in everyone’s everyday life than we think. From the clothes we wear, and the fruit and vegetables we eat, to the smartphones and electric cars we use. All those possessions or processes are contaminated with modern slavery.

The Guardian warns: “Out of the 24.9 million people trapped in forced labour, the majority (16 million) work in the private sector.” Shockingly, statistics from the Home Office reveal a 40% increase in identified potential victims of modern slavery, with 2,320 cases reported between April and June 2019 alone.

But is there anything you can do about it? Fortunately, we all have the power to end slavery by being more ethical in our choices and committing to it.

Read on to discover the core components of a modern slavery policy and learn simple steps to create a clear statement for your own business, ensuring you’re well-prepared to address this major issue proactively and effectively.

What is ‘modern slavery’?

To begin, let’s understand what modern slavery entails. According to the Anti-Slavery International, it occurs ‘when an individual is exploited by others, for personal or commercial gain. Whether tricked, coerced, or forced, they lose their freedom.’

There are several different types of modern slavery that victims may be subjected to, and some may experience more than one at the same time. Labour exploitation remains the most common form of exploitation for both adults and minors (www.stronger2gether.org), underscoring the urgent need for exhaustive modern slavery policies.

Other types of exploitation include:

  • Sexual exploitation: An individual may be forced into prostitution, pornography or lap dancing for little or no pay.
  • Domestic servitude: Someone might be forced to work in a household where they are ill-treated, humiliated, subjected to exhausting hours and live under unbearable conditions.
  • Debt bondage: A person may be forced to work to pay off a debt and it can be used as a means to control a victim.

Do I need a modern slavery policy?

Aligned with section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 (include link to first blog ‘Modern Slavery Act 2015’), all UK businesses with a global turnover of £36 million or more must publish an annual ‘slavery and human trafficking statement every financial year. This affects all types of businesses, including public, private or partnerships, that supply goods or services in the UK. Industries such as construction and manufacturing are no exception, where the risks of slavery are particularly concealed within labour and building materials.

What to include in a modern slavery policy statement

Modern slavery policy statements vary among businesses, yet they must include the following information showcasing the steps taken during the financial year to assess and eliminate risks of slavery, exploitation, and coercion within your organisation and supply chains, even if no actions were taken.

To help, we’ve put together a step-by-step guide outlining five key modern slavery policy requirements based on government recommendations:

Step 1: Policy statement

Create a Policy Statement where you describe your company’s undertakings. Set out the organisation’s intentions toward tackling slavery and show transparency in your businesses and supply chain. Remember to emphasise who is responsible for the policy and publish the statement on the company website (or make it available on-demand).

Step 2: Due diligence processes

Put arrangements in place to describe the due diligence processes in your business about slavery and human trafficking. Check if the existing policies (i.e. Responsible Sourcing Policy, Recruitment/Agency Policy, Supplier Code of Conduct, Responsible Sourcing Policy etc.) relate to modern slavery.

Step 3: Risk assessment & management

Conduct the Risk Assessment to acknowledge the parts of your business and supply chain (labour, materials?) where there is a risk of slavery/human trafficking taking place. Detail the steps taken to assess and manage that risk. Highlight how effective your measures are in ensuring modern slavery and human trafficking are not taking place in your business and/or supply chain.

Step 4: Training

Make sure the word is being spread through the information, instruction and training for all involved.

At a minimum, ensure all personnel are aware and familiar with the company’s Modern Slavery Policy statement. If possible, organise Toolbox Talks on the subject. Remember to explore online resources, as various online platforms offer computer-based training. Subscribe to the responsible person for professional membership with, for example, Sedex, IEMA or ‘stronger2gether’ to receive regular updates on slavery and trafficking.

Step 5: Audits

Monitoring, audit and review your commitments. To boost the confidence that your business is doing what’s needed to tackle the Modern Slavery problem, you should incorporate regular monitoring of the existing procedures. This can be done through internal audits, risk assessment reviews modern slavery incidents reviews etc.

Extra: Check suppliers & sub-contractors

If you rely on suppliers and subcontracted companies, you should have in place a procedure to verify their approach to modern slavery and human trafficking. Making sure they comply with your organisation’s procedures is best practice.

You can also utilise the following: Suppliers PQQ including the organisation’s modern slavery and human trafficking questions, suppliers company modern slavery policy statement or code of conduct, suppliers training on modern slavery, labour recruitment policy, mapping of supply chains and process and supply chain analysis report.

Get compliant with Smas Worksafe

Since 2006, we’ve gained a lot of experience in the field of Health and Safety, helping thousands of businesses manage their obligations with a highly qualified team on hand to help make the process as simple, and smooth, as possible.

If your organisation needs to implement a modern slavery process, SMAS Worksafe has developed a best practice Modern Slavery Statement that can be easily adapted and implemented for any organisation.

Expand your knowledge and achieve compliance with our Worksafe PQQ, SSIP Accreditation schemes, and CITB Training courses today!