The Modern Slavery Act of 2015 included a supply chain transparency requirement for some businesses to produce a slavery and human trafficking statement each financial year. The statement has to include details of what steps the business has taken in that year to ensure that slavery and human trafficking is not present in any part of its supply chain.
The requirement to produce a statement only applies to businesses with a turnover of £36m or more, but even if you’re not required to produce a statement, examining your supply chain and taking any steps you can to ensure it’s free from modern slavery or human trafficking is a good way of being a responsible, ethical business.
In addition to that, many SMEs are part of the supply chain of larger organisations with an obligation to provide a statement. If you supply big business you are likely to be asked about your supply chain, and indeed many bigger businesses may require suppliers to be compliant with their own anti-slavery policies, or to perform extensive due diligence on their own supply chains.
Here are some things you should consider:
Where might you be vulnerable?
There will be some parts of your supply chain which are particularly at risk in this area and you should make sure you understand what these are. Complete a risk assessment of your business so that you know where the problems may lie and can address them. Bear in mind that the problems aren’t necessarily incidences of modern slavery or trafficking, they might just be lack of transparency.
Do you know who’s working for you?
Make sure you know exactly who is working on your behalf. If you use agencies or seasonal staff, make sure you have proof that all the workers involved have the right to work in the UK, and check that the agency you are using isn’t supplied by illegal gangmasters or similar arrangements.
Trafficking happens right here
Don’t fall into the trap of thinking trafficking or slavery won’t be applicable to you if you don’t operate or import from outside the UK. Human trafficking and forced labour takes place here, so make sure you are aware, and if a supplier seems too cheap, think twice before going ahead.
Training and awareness
You may want to consider staff training on how to spot modern slavery, what to do if it becomes apparent there is an issue, and just on awareness of the extent and nature of the problem. There is plenty of guidance available including a modern slavery helpline on 0800 0121 700.
Agreements with suppliers
You should consider asking those supplying you to confirm that their own chains are free from slavery, and possibly incorporate relevant clauses in agreements with suppliers.
If you would like more information, do get in touch.