Getting started with modern slavery risk management
All UK companies with a turnover above £65M need to explain how they assure against the risk of having modern slavery in their supply chain. However it is no secret that many companies are falling a long way behind with respect to their legal obligations in this regard.
Some feel that it is too big a problem to make any start with. Others assume that they are immune. Many do not invest enough. It all adds up to a fairly unimpressive 2% of UK companies who have been deemed to completely and fully meeting their obligations.
Modern Slavery risk assessment is a process not a project. It should be a part of business as usual. So start by doing something and build on that. Here’s a simple set of recommendations about making a start.
MAP YOUR MATERIALS AND SOURCE COUNTRIES
Mapping every supplier in an entire supply chain is daunting, so start with the core materials and components that make up your products and services, and start to document which countries they come from.
Where you procure assembled components, ready-made goods or out-source services, document what you understand about their potential provenance.
USE OPEN SOURCES TO MAKE A FIRST PASS
Then you can start to flag up potential risks. For example if you buy a food product that contains palm oil, or machinery that contains manganese, then by looking up these materials in openly available databases you can start to understand if there are high-risk source countries providing those products.
For example, the ILAB Agency (part of the US Department of Labor) maintains a list of high-risk goods from specific countries. See the latest here.
ASK MAIN SUPPLIERS ABOUT WORKING PRACTISES & CODES OF CONDUCT
There are a number of excellent International standards and codes of conduct regarding Modern Slavery practises. Adopt one and ask your key Suppliers whether or not they comply. Most of them should have a modern slavery checklist of sorts.
Better still, investigate practices that directly relate to the goods you procure and ask if these are specifically checked for and how.
However and wherever you start, it’s important to make a start. Modern Slavery covers a host of practices that would be abhorrent to your customers, shareholders and staff and have no place in a modern business.
Rizikon Assurance is a platform for sending out Modern Slavery assessments, GDPR data processor assessments, Cyber Security assessments and in fact assessments of any type, including those specific to your organisation. You might be interested in having a demo of our Modern Slavery assessment.