Interview with Elaine Mitchel-Hill, ESG & Human Rights Director, Marshalls PLC
Awareness about the extent of human rights abuses in global supply chains continues to grow. According to the latest estimates, 50 million people are living in modern slavery, 10 million more than in 2016. Modern slavery occurs all around the globe, including in the UK, and across the economy, with the highest risk sectors including services, manufacturing, construction and agriculture.
Businesses are now under more pressure than ever from regulators, investors, customers and civil society to show how they identify and manage serious risks to people in their operations and supply chains. Yet so often business can feel paralysed and unsure about where to start. The Social Responsibility Alliance’s Slavery & Trafficking Risk Template (STRT), is an open-source self-assessment questionnaire used by thousands of companies and their suppliers around the world to identify and mitigate risks related to slavery and human trafficking by facilitating accurate data collection. Sancroft’s human rights specialist, Senior Consultant Rachel Weller, has recently been appointed to the Development Committee tasked with developing and updating the tool. In this interview, she speaks with Co-Chair of the Development Committee Elaine Mitchel-Hill, ESG & Human Rights Director at Marshalls PLC, the leading building products company, to discuss what common challenges business face, and how they can use the tool to manage their risks and comply with modern slavery and human trafficking legislation.
1. What common challenges do businesses at the start of their journey face in understanding and mitigating risks of slavery and human trafficking in their supply chains? How can the STRT tool help them to overcome them?
Simply knowing where to start can be a barrier, especially if the supplier base is large and no previous analysis has been done. Lack of knowledge can be compounded by lack of internal support or understanding, not having people in place, and also not having adequate financial resources. The STRT tool provides that ready-to-use jumping-off point for building your knowledge and understanding of where your greatest risks lie within supply chains – you don’t have to reinvent the wheel. For example, regions or commodities where the risks of modern slavery are highest are already identified and embedded within the template, so organisations don’t need to grapple with huge amounts of research before they start. It is also mapped to global regulation such as the UK modern slavery act, US Tariff Act and French Corporate Duty of Vigilance Law and is available in multiple languages so it can be shared with suppliers in multiple geographies.
2. Can you tell us more about how the tool is developed and updated?
The STRT tool is developed and updated annually by the global development committee which includes experts from the private sector, NGOs and workers’ associations, and excellent legal sector representation. This ensures it continues to reflect the growing modern slavery and human rights legislation from a global perspective, latest industry needs, and new research. It also benefits from feedback from the companies and suppliers that use the STRT tool as well as forced labour experts and others. In 2021, which was the International Year for the Elimination of Child Labour, we sought the input of leading experts such as the International Labour Organization, and UN Global Compact to review the STRT through a child’s rights lens.
3. Can you tell us more about how you integrate the tool into Marshall’s’ existing supply chain due diligence systems?
We have six initial key questions built into our procurement due diligence process, which we refer to as the ‘STRT filter’ as it’s not the entire STRT assessment. This helps flag potential areas of risk at an early stage so that the business & human rights team can conduct additional due diligence and monitoring. We have also built the STRT into our own audit platform and can access it from hand-held devices out in supply chains. From here we can request that that suppliers or potential suppliers complete it, or we can walk them through its completion. Being built into our system allows us to easily follow up on outstanding documentation, monitor corrective actions and ensure further follow-ups. The STRT tool also works well in its existing excel form allowing some of our suppliers in higher risk geographies to share this with their own suppliers and receive the findings back in a consistent way which makes analysing them easier. A key tip would be simply to start using it however you’re able as it will help you identify areas of risk. This then empowers you to take action when you identify that risk.
4. Integrating respect for human rights into the business and procurement decisions is critical to ensure that business’ investment in human rights is effective, both for people and for the business. How have you approached this at Marshalls?
We’ve developed what we refer to internally as a ‘three-legged-stool’ approach to human rights from a supply chain due diligence perspective which has proved very successful. It’s a very practical and hands-on approach which rests on the ‘three legs’ of human rights, procurement and commercial. Essentially no procurement or commercial decision can be made without discussing and understanding the human rights implications and challenges. It’s an approach understanding designed to ensure we fully understand the risks and issues, agree next steps after assessing the information gathered, and build internal understanding of the human rights implications. It also drives us to work more closely together to ensure best practice, deliver an economic benefit to partners in the supply chain and ensure that monitoring, reporting and remediation are all swift. It drives a richer understanding of the specific challenges of colleagues in different part of the business, ensures that human rights is a fundamental part of the process and delivers good human rights outcomes
What advice do you have for other businesses that are starting out on their journey?
My top 10 tips would be:
- Analyse your supplier base so that you’re clear where your highest risk lies and what the salient issues are for you.
- Direct your time and available resources to these areas.
- Get out into your supply chains often – you need to see, here, smell and experience your supply chain. You can’t do that from behind a desk.
- Don’t rely on audits alone – be creative and adaptable in your response; one size definitely doesn’t fit all.
- Join influential networks with like-minded peers and experts which allow you to compound any impact
- Look for cross- sectoral initiatives as well as those within your own sector many of the root causes are universal, so the solutions can be as well.
- Don’t take no for an answer if you believe your organisation can and should do better – be intelligent and create a strong business case for your suggested approach.
- Always be mindful of the best interests of the workers and communities affected by your organization – the rights and dignity of workers are what’s important, not just good-looking compliance analytics.
- Be prepared to be consistent, persistent and in the for long-haul – it’s a marathon my friends, not a sprint. I’ve been working on the issue of child labour in India since 2005, and some of the biggest positive steps have come very recently.
- Build a phenomenal business and human rights team within your organisation, and a strong and smart network globally – you’ll need them by your side on this journey, because if you do it right, it’s hard – but it’s absolutely more than worth it.
Sancroft can help you understand what the growing focus on human rights means for your organisation and to develop an action plan to strengthen your management of human rights risks and opportunities – in a way that brings value to your organisation. To find out how we can help you, please contact Rachel Weller.
You can read more about, and download the STRT tool here and listen to the podcast series which covers topics including data driven human rights due diligence, Uyghur forced labour and just transition.