Modern Slavery policy in 5 quick steps

By Anna Haag – SMAS Worksafe Assessor

Slavery is not a thing of the past, the problem is still hurting us today.

“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. Unfortunately, the problem is more engraved in everyone’s everyday life than we think. The clothes that we wear, the fruit and vegetable we eat, the seafood we buy in the supermarkets, our smartphones and electric cars. 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.”

The Home Office has reported that 2,320 people were identified as potential victims of modern slavery between April and June 2019 a 40% increase on the same quarter in 2018. Labour exploitation remains the most common type of exploitation recorded by the UK government. for both adults and minors. –

Let’s put it out there, the construction sector is also in danger. The two biggest risks of slavery hide under labour and building materials. But is there anything you can do about it? Fortunately, we all have the power to end slavery, simply by being more ethical in our choices and committing to it. Why not try to tackle modern slavery in your business today?

Step 1
Your commitment to tackle the problem through the Policy Statement is the key.
Create a Policy Statement where you describe your company’s undertakings, set out the company’s intentions toward tackling slavery and show transparency in your businesses and supply chain. Remember to highlight who is responsible for the policy and publish the statement on the company website (or make it available on-demand).

Step 2
Put arrangements in place such as describe the due diligence processes in your business in relation to 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. 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 is not taking place in your business and/or supply chain. Point out the training that has taken place either directly within the organisation or with suppliers and others, helped to better understand and respond to the identified slavery and human trafficking risks.

Step 3
Make sure the word is being spread through the information, instruction and training for all involved.
At a minimum, make sure all personnel is 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 the responsible person for professional membership with for example, Sedex, IEMA or ‘stronger2gether’ to receive regular updates on slavery and trafficking.

Step 4
Monitoring, audit and review your commitments.
To boost up 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 and modern slavery incidents reviews etc.

Step 5
Don’t forget about checking your suppliers and subcontracting companies.
If relying 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 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.

Think ethics. Act now.

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