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What can you and your organisation be doing when it comes to Modern Slavery?

The Modern Slavery Act has now been around for 5 years. The cynics said it would be just another ticky-box exercise for businesses and fundamentally nothing would change. Whilst I don’t believe there has been enough of a change, it has contributed to raising awareness and therefore helped with a shift that is currently happening.

Customers are now more aware about the type of companies they want to buy from, and employees care more about who they work for. People are realising that Modern Slavery is not beyond the realms of possibility, happening somewhere far away and not relevant to them. These types of incidents occur in every part of the UK.

Who can forget the tragedy of the 39 Vietnamese people found dead in the back of the Essex or the press reports of Boohoo and sweatshops in Leicester? There is no denying this is a sad reality on our doorsteps but there are more day to day examples that you will see, if you start looking.

As seems to be the way with this type of legislation, the main onus is on the bigger organisations to do more. Those who turn over more than £36million must monitor and report on their supply chains. They can afford teams of people to ensure they have the right statements published, are investigating concerns straight away, conducting reviews and audits and doing their due diligence. They won’t always get it right and they should certainly not rest on their laurels as there is always more they could be doing.

Smaller organisations shouldn’t feel it is something they don’t have to concern themselves with. If they are part of the supply chain of an organisation that turns over £36 million, then there will be contractual requirements now upon them.

In the main most organisations are good at being compliant with the conditions bestowed upon them by the Modern Slavery Act, but if more care was taken to go beyond this, and organisations really looked, it wouldn’t be hard to find examples. All organisations, large/small, established/start-up should be looking to go beyond the legislative requirements.

Rob Chesnut – author of Intentional Integrity, points out, the world is recognising we need companies to step up and fix the problems in the world. Politics and legislation doesn’t seem to be enough. Running a business is no longer just about shareholder value and turning a profit. ESG (Environment, Sustainability and Governance) is critical and has to be at the forefront of business leaders minds. You don’t need to take his or my word for it. Research by Ethisphere shows that ethics and financial performance go hand in hand with those listed as The World’s Most Ethical Companies in 2020 outperforming by 13.5% over 5 years and there is a lot more research out there that supports this.

At the pointed end of this chain, organised criminal networks are making people’s lives hell and they are profiting hugely from it. Quite often the fear of finding out that there are links to this with your company, relate to the negative PR issues but if you proactively seek it out, and then deal with it, then shareholders and customers alike, will have confidence that your organisation is responsible and committed to ESG.

Modern Slavery should no longer be a taboo subject that no one mentions until they are having to defend themselves. Accepting that there are risks within your supply chain (and beyond) is helpful. Think about the business, your business does business with and map out where the potentials for these risks are.

Key questions I would ask are: Is there transparency there? Did you do your due diligence at the time of signing with them? Is this something you do at regular intervals? What mitigation could you put in place? What do you do to protect the people in your supply chain? What options do their people have for speaking up if there are problems and what measures are in place to investigate these concerns?

Do remember this goes beyond the supply chain, so apply the same thought process closer to home and to your own organisation.

If you are keen to read more about Modern Slavery, I found the Ethical Trade Initiative, the Business & Human Rights Resource Centre and the Gangmasters and Labour Abuse Authority really useful sources of information.

I recognise that this isn’t just about finding problems and correcting isolated incidents. Trying to understand the systemic issues which creates this risk, will have much more of an impact. There are responsibility experts out there who are passionate about driving positive change in this area, it may be your organisation is ready to have an inhouse expert or someone you consult with.

If you have concerns about anything happening with your supply chain, or you simply aren’t sure, we can conduct audits and investigations. We can also support you with building your Ethics and Compliance Programmes. Get in touch here.


I’ll leave you with the words of Oscar Arias Sanchez “The more freedom we enjoy, the greater the responsibility we bear, toward others as well as ourselves.”

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