In November 2019 I attend a meeting to explore the idea of developing a British Standard to address modern slavery both within an organisation and its connected supply chain. During Q1 of 2020 the decision was made, and work started on pulling this standard together.
I say pull together, that phrase does not do justice to the 2 years of blood, sweat and tears that has been spent on developing what is one of the first standards in this space. The committee has been made up of businesses, academics, and standard writers to ensure that it addresses best practice but in a pragmatic way that can support successful implementation.
You may be familiar already with the imminent standard – BS25700 – the organisational response to modern slavery. You may have watched the webinar earlier this year – BS25700 Organizational Responses to Modern Slavery, if you’re in my LinkedIn network you will have seen me talk about it at length.
I truly believe that what has been finally approved on July 12th 2022 is a really instructive and useful framework for organisations to follow when determining how to manage the risk and impact of modern slavery both at organisational level and in connected supply chains.
It has several useful aspects that I think will help with the success of implementation:
- On our committee we had a modern slavery survivor, someone with lived experience who kept the group grounded and ensured that through the heart of the standard was the focus on people, not just organisational and supply chain processes.
- The standard is a guidance standard in nature. Whilst I know that concept is sometimes divisive amongst the business community, contrary to popular belief, addressing modern slavery is not a compliance issue and needs a nuanced approach to implementation. The guidance approach allows that.
- This flexible approach means that the standard can apply to businesses of any size and within any industry and enables organisations to adopt an element of consistency when trying to address the issue.
- It’s holistic. It covers the whole of the organisation and it’s supply chains. This means that it not only looks at supply chains but also ensures that businesses are driving the necessary behaviours and requirements within their own structure, systems, and culture. In my last few years helping businesses in this area, I have found that organisations either focus on themselves or dive straight into the supply chain and very rarely in a holistic and structured way.
- It was written in a way that compliments an organisation’s management systems as well as ensuring compatibility with other interconnected issues and standards. As you are aware I have spent a lot of my career helping businesses with sustainable procurement and the ISO20400 standard, along with standards on social responsibility, risk management and whistleblowing (amongst other) all helped influence the final content.
Whilst this is one of the more comprehensive standards developed, it reflects the fact that an organisations response to modern slavery is not just the purview of the legal department or the procurement teams, but is something that should run through the lifeblood of any organisation.
BS25700 – the organisational response to modern slavery is one of the first standards within the modern slavery space.
The standard covers several areas that organisations must consider, and I will look at most of these areas in more detail over the coming months. It focuses on:
- The role of leadership and management – ensuring that the top teams in organisations understand exactly what modern slavery is and how their organisation will address the issue in it’s policies and decision making.
- Policies – not just specific modern slavery polices, but the connection with interdependent areas such as HR, procurement, and even area like sustainability.
- Resourcing – one of the biggest mistakes organisations make, is thinking this is something that can be added to an audit or is just as simple as adding a compliance requirement on a purchase order. The reality is that there will be some need to look at whether resources are sufficient to drive the necessary behaviours and understand the risks and impacts of modern slavery both within the organisation itself but also within the supply chain. The standard provides guidance on what that resource profile looks like.
- Training – raising awareness never stops and training is a key part of that but the standard pushes organisations to develop a training plan that goes beyond just awareness raising but also improving competence to implement the necessary steps to address the risk of modern slavery.
- Recruitment & Employment Relations – modern slavery occurs where vulnerabilities exist and for that reason organisations need to look long and hard at their employment standards and those of their supply chains. Included in all of this though is the importance of the workers voice and ensuring that people who work directly for the organisation or are part of the connected supply chain have an opportunity to be heard and issues addressed.
- Procurement & Supply Chain – the standard not only addresses the technical aspects of procurement such as the plan, the source manage process, but looks deeper into concepts such as supply chain mapping and supplier development to ensure that there is comprehensive guidance on due diligence and the various strategies needed to provide this.
- Whistleblowing & Remedy – an area a lot of organisations don’t consider is what happens if I find instances of modern slavery. Included in the standard is guidance on what whistleblowing mechanisms should be in place and what remediation looks like.
- Performance management – it outlines both how an organisation should measure and evaluate the success of its modern slavery mitigation activity, as well as how it should develop a continuous improvement approach to implementation rather than a singular compliance approach
There are also sections on risk management and assessment, and the role of audits, I could seriously go on, but I would be in danger of writing an essay. Simply put it’s comprehensive.
I have had an engaging, enlightening, and inspiring 2 years helping to develop and write this standard. Whilst sometimes the micro details have sent me mad, the process for developing has been rewarding and hopefully will provide organisations with a framework they can use that goes beyond awareness raising activity and drive true action in the fight against modern slavery.
On the 15th September, Helen Carter will be hosting a FREE webinar alongside fellow speakers who helped write the standard to provide your organisation with guidance on how you can develop your own organisational requirements to embed effective modern slavery due diligence.
Secure your free place here.