Earlier this month was Anti-Slavery Day, and we are seeing signs of many actors – from government to industry – stepping up their actions to tackle modern slavery. This is having a stronger impact on businesses – from securing better scoring in government procurement bids, to restriction of imports where due diligence on modern slavery has not been followed.
Public procurement has a strong role to play in tackling this issue, given the scale of Government spend – as highlighted in the Sancroft-Tussell report we released earlier this year. And now, following pressure, the Cabinet Office has released official guidance for public procurement departments to ensure this serious issue is tackled. The advice recommends what questions Government procurement needs to ask of suppliers, and how failure on these can be cause for deselection of companies that do not meet modern slavery reporting guidelines. Businesses will now face direct incentive to report robustly, as a competitive advantage – demonstrating the government’s commitment to lead by example – central government will also be publishing their first modern slavery statement by end of the year.
Building on this momentum, earlier this month, Dame Sara Thornton, the Independent Anti-Slavery Commissioner, published her office’s strategy for the next two years. The strategy outlines four priority areas: improving victim support and care; supporting law enforcement and prosecutions; focusing on prevention; and getting value from research and innovation. Thornton plans to focus on prevention by working with the private sector to raise rates of compliance and overall performance through reiterating compliance requirements and establishing a central registry of modern slavery statements.
The recent rise in pressure has not just been felt by the public sector – the University of Nottingham Rights Lab published a report highlighting the continued prevalence of modern slavery in the agricultural sector. Some of the biggest issues are around the payment of recruitment fees by workers and excessive working hours, although there is a lack of formal data in the UK. The report acknowledges that more companies are producing a statement than ever before but warns that overall quality is not improving. In fact they note that average quality is falling, as early adopters are making little improvement, and latecomers are coming in with low quality statements, rather than learning from best practice.
All organisations – not just within the agricultural sector – will have to pay more attention to modern slavery risks, ensuring they are taking meaningful action and demonstrating this in their modern slavery statements, going beyond a tick-box exercise. Not only is this required by stakeholders, but the extreme alternative is supply chain disruption – like in the recent news story where goods to be imported into the US have been held at the border due to evidence that they had been produced using forced labour. This shows that across the world in complex supply chains real action is now being taken on issues of modern slavery and forced labour – they are no longer simply questions of theoretical compliance and reputation management.
Taken together, these developments represent renewed momentum in the fight against modern slavery. The University of Nottingham’s report flags that there is still serious work to be done, particularly in the higher risk sectors like agriculture. Organisations should be mindful of similar report recommendations and think how they can take a risk-based approach to managing modern slavery risks in their supply chains. This will become increasingly important as sanctions similar to those in the US last month become more common, while greater focus and higher expectations mean companies can get ahead of competitors by demonstrating their proactivity.
How can Sancroft help your business?
Sancroft has extensive experience in supporting our clients on the topic of business and human rights. We can help you to:
- Draft your modern slavery statement and support your response to legislative requirements
- Undertake a mapping and gap analysis exercise against international legislative requirements and standards
- Carry out a comprehensive human rights risk assessment at the business, country or commodity-level to understand direct and indirect human rights risks and develop a holistic human rights programme
For more information, or if you would like to discuss what this means for you, please email firstname.lastname@example.org
Upcoming complimentary event and report
Rising expectations on human rights are one part of the broader changes supply chains are experiencing – disruption that brings new opportunities for stronger management and better connection with stakeholders. We will be hosting an event on the 6 biggest shifts – and how companies are adapting to them – on the morning of 6th November.