The Modern Slavery Act, passed into UK law in March, is the first of its kind in Europe, and one of the first in the world, to address slavery and human trafficking in the 21st century. It includes a Transparency in Supply Chains Clause, which as of October will require companies with a turnover of more than £36 million to publish an annual slavery and human trafficking statement. This turnover threshold will affect over 12,000 companies and their UK and international supply chains.
In this statement a business must describe the steps they have taken to ensure that slavery and human trafficking is not taking place in any of their supply chains or their own business, or they must disclose that they have taken no such steps.
The requirements of the Act mean that companies truly need to have an understanding of what is happening in the deeper tiers of their supply chain and to be able to demonstrate that they have due diligence processes in place to ensure that slavery and human trafficking is not taking place in their own operations or supply chains.
Sedex — the world’s largest collaborative platform for managing and sharing sustainable supply chain data — provides its 38,000 members in 150 countries with a range of multi-tier supply chain mapping solutions to help them identify, measure and manage risks in their supply chains. Sedex’s platform helps to drive transparency and supply chain visibility — a critical step in understanding who suppliers are and supporting the evaluation of risk. When joining Sedex, suppliers are asked to complete a questionnaire (the Self-Assessment Questionnaire or SAQ) which could provide the first indication of management systems gaps, or forced or bonded labour risks, such as lack of information about labour providers, holding of identity documents, wage deductions, etc. These issues can then be addressed further, often via a third-party audit.
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The Sedex platform enables members to report on trends across their supply chain and look for possible self-assessment or audit non-compliance indicators of forced or bonded labour that might seem innocuous when viewed individually, but which once combined can paint a different picture. Furthermore, we partner with global risk analytics experts Maplecroft, which reference hundreds of indices from human rights violations to political risk factors to flag country and industry risk factors.
Many companies are already working on their statements to ensure that they are in place for their next annual reporting cycle. What is your business doing to ensure its supply chain is free from human trafficking? For more guidance on identifying and tackling risks related to human trafficking and modern slavery, see our Modern Day Slavery briefing and the Sedex Supplier Workbook, and Walk Free’s comprehensive guide, “Tackling Modern Slavery in Supply Chains.”