By Joanna Frost
3rd May 2017
Eversheds Sutherland recently published an article looking back at the first twelve months’ slavery and trafficking statements, which is an interesting read especially for those to whom the Act applies.
The article provides information on the UK’s Anti-Slavery Commissioner’s assessment of how organisations have responded to the Act. He believes that the Act has increased senior management awareness of modern slavery, however he characterised many of the initial slavery and trafficking statements as weak. He urged employers to do more to understand and to mitigate their industry specific risks and to provide greater information in their statements on how they are responding.
The article goes on to explain that The Business and Human Rights Resource Centre registry of modern slavery statements typically show good reporting by businesses on their anti-slavery policies but poor (or non-existent) reporting when it comes to training, due diligence, risk assessments and measuring performance. Those with procurement responsibility have a key role in due diligence and risk assessment activities to eliminate modern slavery in your institutions supply chains. This may include carrying out an assessment of existing suppliers to identify those that are likely to pose a higher risk in terms of modern slavery and trafficking occurring in their supply chains and working with them to encourage them to work at reducing this risk; amending procurement processes to ensure new suppliers are evaluated (where appropriate) on their approach to reducing risks of modern slavery and ensuring any procurement policies are embedded throughout your institution.
A good example of other activities being carried out in our sector is the work being undertaken by Procurement Manager, Claudia Johannes at Hadlow College Group who saw the opportunity to work with the National Centre for Diversity to build a modern slavery element to their supplier accreditation support package, so the E&D accreditation the College obtains would cover both requirements. Claudia was recognised for this work and was nominated for UK’s Resources/ Procurement Manager of the Year Award 2017 at the recent National Centre for Diversity Grand Awards.
The article also discusses the growing reputational risk from Modern Slavery and highlights 6 actions taken by pressure groups, consumers, investors and/or parliament over the last 12 months to compel organisations to take action.
As a reminder, The Modern Slavery Act (‘Act’) requires institutions with an annual turnover of not less than £36million to publicly report, in a slavery and trafficking statement, the steps they have taken to ensure their operations and supply chains are trafficking and slavery free.
For more information on the requirements of the Act and how CPC can help you comply, please refer to our previous newsletter article and information on FELP which includes details of the Chartered Institute of Procurement and Supply Chain (CIPS) ethical procurement training module.