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How to minimise modern slavery risks in your supply chain


During September the Government Commercial Function issued a new Procurement Policy Note (PPN) on identifying and managing risks of modern slavery in both existing contracts and new procurement activity. Whilst it is not mandatory for schools, academies and colleges to follow the guidance in this PPN, those wishing to strengthen their practices in this area may wish to consider a similar approach to that outlined in the guidance.

Steps to minimise risks:

  1. Ensure those involved in purchasing are trained in identifying modern slavery risk and the steps to tackle it effectively. The guidance recommends the CIPS Ethical Procurement and Supply e-learning module. CPC members can access the CIPS Ethical Procurement training module for free as part of CPL Group’s continued reinvestment back into the education sector! Please visit Crescent Learning to find out more.

  2. Use a Procurement Planning Checklist as a reminder of the key things to consider before a procurement commences. Should you use a CPC framework agreement to procure your goods or services a number of the checklist items have already been carried out by CPC saving you time and effort e.g. checking a suppliers mandatory exclusions relating to modern slavery offences, and that those who are required to comply with the Modern Slavery Act 2015 are doing so.

  3. Where relevant include in your terms and conditions of contract your right to carry out site visits and/ or receive management information from your appointed supplier on what they have done and are continuing to do to identify and address modern slavery risks in their supply chains - model contract clauses are provided in the guidance.

  4. Tender Evaluation - The guidance provides practical examples of the type of questions you could ask of bidders to respond to in their tender submissions that will help encourage bidders to do due diligence on their supply chains and how you might evaluate these.

  5. Existing Suppliers – ask your suppliers to complete the Modern Slavery Assessment Tool which has been designed to help public sector organisations work in partnership with suppliers to improve protections and reduce the risk of exploitation of workers in their supply chains. It also aims to help public sector organisations understand where there may be risks of modern slavery in the supply chains of goods and services they have procured.

This guidance is recommended reading for anyone wishing to improve their organisations approach to modern slavery risks and essential for those institutions whose turnover exceeds £36m and are themselves subject to The Modern Slavery Act 2015.

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