1. Go beyond the bare minimum
Make human rights and the fight against modern slavery a central part of the company and act accordingly. Devise the appropriate policies, train employees and create awareness. Everyone needs to know what modern slavery is and what the dangers are, and how likely it is that the company may be allowing it in its supply chain without even knowing it. And be clear on what the company’s legal requirements are.
Map what your company is already doing. There might be steps that are being taken that are useful and could be a good steppingstone.
3. Supply chain assessment
Map your supply chain and check if you can trace your products to its primary source. There might be particular risk countries or problematic raw materials you are working with for which you might need to be extra careful. If so, what can you do to manage that risk?
A lot of work has been done and there are plenty of instruments available for addressing modern slavery. Learn about innovative tools and software being used and decide which is the best for your company.
4. Establish a procedure for monitoring and auditing
Due diligence implies having a plan of action and someone in charge of carrying out.
Monitoring of suppliers is an important step for ensuring that suppliers are compliant. Ideally, monitoring would somehow include other tiers of the supply chain.
5. Re-think the working relationship with suppliers
Modern slavery has more chances of ending if longstanding relationships are built with suppliers. This means that more clear guidelines and policies can be established and that compliance can be more easily monitored and suppliers can be encouraged to strive for more transparency.
Important: if elements of slave labour are found, then work with suppliers to address these issues, not just find a new one.
6. Track success and failures
It is important to know what has worked and what hasn’t. What are the challenges that are most difficult to overcome? What alternatives are available?
7. Think about remediation
It is possible that you discover your company is inadvertently using slave labour. What will you do? How will you compensate and protect workers you find in such conditions? How will you prevent this from happening again?
See also: Compliance with the Modern Slavery Act: a matter of TRIVIAL PURSUIT?
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