Can you standardise Modern Slavery? By Helen Carter

No, I am not encouraging you to start thinking about how to make Modern Slavery efficient.

There is a conversation going on within business and political circles on whether there is a need for a modern slavery standard to be created or not.  The aim of it? To help businesses meet their compliance requirements whilst navigating the challenging waters of supply chain transparency. More specifically, relating this proposed standard to Section 54 of the Modern Slavery Act 2015, which requires organisations to develop a slavery and human trafficking statement each year.  A tricky discussion perhaps?

In today’s ever-changing world, the moral imperative for businesses to be socially responsible is rising higher on the agenda, not to mention the increasing legislative requirements that need to be met. As I recall my first forays in sustainable procurement training, you can overwhelm and startle an individual to act by exposing the world and all its seedy practices.  A person naturally supposes, ‘what can I, as an individual, do to really make a change?’

Awareness around labour exploitation is at an all-time high since the introduction of the Modern Slavery Act three years ago. I alone, have led workshops for over 800 individuals in that period. Despite all the hype, supply chain transparency remains one of the biggest challenges for any business to address.

Supply chain transparency is a challenging and complex subject, hence there is a natural tendency to want to standardise and simplify the approach. Find models and metrics that can be used to make everyone’s life a little easier.

Can a standard really work, though?

The cons:

• Businesses are complex and diverse. From working in procurement for over 20 years I can tell you that supply chains come in all shapes and sizes. From the mechanised and (almost) linear, to the mega-complex and intricately tangled. For instance, looking at an automotive production line is barely comparable to an office block development in terms of supply chain management and processes. Believe me, over my 20 years in construction, many have tried and failed to replicate manufacturing supply chain processes.
• Combatting slavery must become part of the business as usual dialogue for any real change to occur. This involves some real cultural change and undoubtedly difficult conversations at board level.  It’s easy to focus on the low-hanging fruit, such as transient and temporary labour improvements.  But how far down the supply chain do you go? And how do you utilise tight resources? Most certainly, the familiar question around ROI will repeatedly come up.

• Resources, resources, resources. Taking the time to first understand the modern slavery issue, then dedicating resources to enable the organisation to effectively tackle it, and, more importantly, working with the supply chain to increase transparency – it all takes time, dedication and significant investment. Companies that are nervous over being found out over dubious circumstances are quick to put in tick-box activities. They would, no doubt, welcome a standard so their PQQ process becomes easier (nay cushier) to navigate and certificates can be hung proudly on the wall. A standard, if used improperly, can ceremoniously defeat the object of embedding a more socially responsible approach to doing business.
• Delegating responsibility could be an issue. Procurement professionals need to explicitly understand the context of a standard they are requesting as part of procurement activity, and not resort to it as a process allowing them to delegate their own responsibility down the supply chain – I see this happen often in procurement – ‘Have you got the standard? Good, I can breathe easier now.’

The pros (IF written and verified correctly):

• Standards provide a good basis and framework for organisations to follow if they are unsure where to start. In my three years of training organisations, there is an appetite to do something tangible, but a lack of clarity on the steps needed to address the issues.  Often, companies don’t deal with these issues daily, so they really need as much support as they can get their hands on.
• A standard or framework can provide an opportunity for sector-specific initiatives to integrate into the mitigation process and subsequently, can build on collaborative efforts that are already established or underway
• Feeding down the food chain. A standard can be utilised by an organisation’s complex supply chain to evidence activities and successes in this area, and if accessible, can even help SMEs to deliver real change which wouldn’t normally be possible.

Simply put (if you can simplify a complex issue), succeeding in supply chain transparency is good supply chain management, and in reality, there are a wealth of standards and organisations out there that provide guidance. Anyone in procurement will tell you that the transparency challenge is a very long and arduous slog and, in some cases, feels like a time-consuming and thankless task. Combating slavery within your supply chain could take you 10, 15 or even 25 years – just ask Marshalls or Marks & Spencer.

So what do successful organisations have?

1. A clear understanding of what targets they are trying to set for human rights and socially responsible business practices.

2. A published commitment relating to what they are trying to achieve in terms of ethics, human rights and modern slavery.

3. Enabling their organisation to understand the issues relating to human rights, slavery and other ethical issues, identify their hotspots, prioritise their resources accordingly, report on progress and ensure that they engage with peer organisations and other interested stakeholders.

4. Employees and supply chain partners who are supported by whistleblowing and other support facilities that are transparent, fair and link to the steps necessary to help victims if they are found.

5. Procurement channels that are developed to ensure there is understanding on modern slavery. The end ambition is to create an open and transparent supply chain where necessary, to ensure that they are starting to identify and combat slavery where they can.

Now I will let you into a little secret ……that success framework is called ISO 20400….

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