Modern Slavery Statements: What is continuous improvement and how can we strive for it?
With many of our clients in their second or third year of modern slavery reporting, we’ve been looking for opportunities to help accelerate their modern slavery risk management and due diligence programs to demonstrate how they are practically addressing the issue and striving for continuous improvement. Many aspire to be leaders in their respective sectors (we love those clients) and take tangible action to ‘walk the talk’. We work closely with clients to develop modern slavery risk management road maps which enable them to prioritise actions and hold themselves accountable year-on-year.
The expectations of Boards, customers, investors and other stakeholders continue to increase. Companies who state they are still trying to understand the risks, who are writing policies, requiring suppliers to sign Codes of Conduct, or contractually obligating suppliers to warrant there is no slavery in their supply chain (which we consider impossible, unrealistic and a meretricious legal exercise in outsourcing responsibility) may find themselves under greater scrutiny by governments, academics and civil society.
Here’s a few suggestions on how organisations can ‘step up’ and meet increasing expectations:
Provide and promote an accessible grievance mechanism and victim centred remedy pathway and inform and educate internal and external stakeholders.
Develop and publish case studies on challenges faced when assessing and addressing modern slavery risks such as engaging suppliers who themselves are not reporting entities.
Publish a list (or map) of key suppliers, their locations and the goods or services procured.
Effectively engage priority Tier 1 suppliers to help map Tier 2 (and even Tier 3 suppliers) to better understand risk in the extended supply chain.
Make modern slavery training available to high risk / priority suppliers.
Model future potential risk based on procurement forecasts, tenders and budgets.
Undertake real consultation with entities you own or control and engage them in modern slavery planning and risk management process.
Identify and engage relevant (in country) community groups, NGOs (or unions) associated with workers in your supply chains.
Pilot a worker voice program with priority Tier 1 or Tier 2 suppliers.
