The Modern Slavery Act 2015 tackles the real issue that is modern day slavery:

• holding a person in slavery or servitude;
• requiring a person to perform forced or compulsory labour;
• arranging or facilitating human trafficking.

The act defines the offences and their penalties but goes beyond that to legalise the requirement to put steps in place to prevent modern day slavery – this is where it impacts on a large proportion of UK businesses.

Section 54 of the Modern Slavery Act 2015, Transparency in supply chains etc., requires commercial organisations to prepare a slavery and human trafficking statement for each financial year.

Those of you trading in the State of California will be familiar with this as it follows very similar lines to California Transparency in Supply Chains Act of 2010. The required statement will describe the steps the organisation has taken during the financial year to ensure slavery and human trafficking is not taking place in any of its supply chains and in any part of its business.

Alternatively the organisation can provide a statement to say it has taken no such steps.

What constitutes a ‘commercial organisation’?

• supplies goods or services;

• has total turnover of £36 million or more;

• carries on a business, or part of a business, in any part of the United Kingdom.

What do you have to do with the statement?

• get it approved by the board of directors (or equivalent) and signed by a director (or equivalent);

• publish it on your organisation’s website;

• link to it from a prominent place on the homepage.

When do I need to do this by?

The first companies required to provide a statement are those whose financial year ends on 31^st March 2016. They will be required to report on their 2015/16 financial year and there is an expectation that organisations will have published their statement within six months of their year-end although this isn’t stated in the legislation.

Organisations whose year-end is before the 31^st March 2016 don’t have to provide a statement for their 2015/16 financial year.

Beyond compliance?

This isn’t just a compliance issue. Finding slavery and human trafficking issues in your business or supply chains will have more than just legal consequences, it will have massive commercial consequences as well – reputation loss; brand damage; loss of sales; increased scrutiny and investigation (and the associated senior management time that entails); loss of ethical investment; and the inability to attract top talent are just some of the consequences awaiting organisations who don’t address this issue.

Next steps...

The legislation obviously presents you with the option to do nothing however you decide you are going to take steps how do you start?

Identifying slavery and human trafficking issues in the supply chain is a big ask and it is understood that it is impossible to absolutely guarantee that it isn’t happening. Organisations need to take a risk based approach but also be constantly monitoring and responding to global changes.

You will need to map your supply chains taking into consideration:

• Where is your biggest spend?
• Where do you have the most leverage (this will tell you where you have the most responsibility)?
• Which countries or regions are in your supply chain?
• Which sectors are you dealing with?
• Is there a regular use of temporary labour?

Having mapped your supply chain and identified your greatest risk areas you will then need to carry out a due diligence exercise to understand your impacts. The UN guiding principles on business and human rights and the UK Government’s Good Business: Implementing the UN Guiding Principles on Business and Human Rights are the ideal place to start but you will also need to find others to organisations collaborate with (human rights is considered to be a pre competitive issue) and experts in the field who can help and guide you.

Once you have the results of your investigations you will need to respond with policies and procedures to mitigate the risks; embedding activities; and steps to eliminate any issues you have found find.

RiskHorizon™

RiskHorizon™ helps you understand, evaluate, prioritise and take action on external risks. It is the first web tool to quantify and monetise sustainability risks and will help you assess you value at risk, prioritise actions for implementation to reduce your value at risk, and measure the social impact of ‘doing good’. This is the perfect tool to help you kick start your response to managing slavery and human trafficking.

To find out more about  RiskHorizon™ contact Fiona Place.

In addition, Anthesis offer broader Social Impact support, assessing your impacts, measuring your Social Value, developing your response, quantifying the risks and developing your message.

To find out more about the Anthesis Social Impact offer contact Chris Stanley to discuss your needs.

And we help you to go beyond compliance to embed responsible procurement into your business to realise cost savings, reductions in supply chain risk, and better supplier relations. Our services cover procurement strategy and policy development; auditing and process improvement; supplier engagement and development, capability building and training. Our accredited Responsible Procurement Code and CIPS Sustainable Procurement Review will baseline your performance and prioritise your next steps.