Due diligence in modern slavery: Eight myths debunked By EJ Allen

Due diligence is about being proactive in your approach to identify, prevent and mitigate the risks of forced labour and labour exploitation in your operations and supply chain. It’s about understanding and addressing those risks, with a focus on prevention, remediation and transparency.

However, there’s a lot inaccuracies and myths when it comes to modern slavery and human rights due diligence. Here are eight of the most common:

1. Myth: Due diligence is a one-time event

Fact: Due diligence is an ongoing and dynamic process that requires continuous monitoring and evaluation. It’s not a one-off task – it’s a proactive approach that you need to embed into your operations and supply chain management processes.

2. Myth: Due diligence is only necessary for high-risk industries or regions

Fact: Modern slavery can occur in any industry, anywhere in the world. Yes, some industries or regions are considered higher risk, BUT, due diligence should be conducted across all categories of spend.

Take the case of solar PV panels, just because you don’t have any extended PV  suppliers in the Uyghur region of China –  where forced labour is prevalent – doesn’t mean there’s zero risk of forced labour or labour exploitation in your solar PV panels supply chain.

3. Myth: Compliance with legal requirements is sufficient for due diligence

Fact: While legal compliance is essential, it’s not enough to address the complexities of modern slavery. Effective due diligence goes beyond legal obligations and involves assessing risks, engaging stakeholders, and implementing proactive measures to identify, prevent, mitigate and remediate modern slavery throughout the supply chain.

4. Myth: Due diligence is the sole responsibility of procurement or supply chain departments

Fact: Due diligence is a shared responsibility that requires collaboration across various departments, including procurement, legal, human resources, and corporate social responsibility. You need a multidisciplinary approach to effectively identify and mitigate risks.

5. Myth: Due diligence is too costly and time-consuming

Fact: Yes, implementing robust due diligence processes can require upfront investment and resources, but ultimately it can save costs by preventing reputational damage, legal liabilities, and business disruptions associated with modern slavery incidents.

Not convinced? Spend a few minutes searching for due diligence legislation that will impact your international supply chains, or organisations that have been named and shamed for their links to modern slavery or labour exploitation. You’ll be surprised by how much you find.

6. Myth: Audits provide all the answers

Fact: They don’t! They are just one piece of the puzzle and can’t single handedly address the complex issue of modern slavery.

7. Myth: If you discover a case of labour exploitation or modern slavery in your supply chain, the best thing to do is to cut all ties immediately with that supplier

Fact: Don’t react with a knee jerk response – talk to the supplier to find out what happened, why it happened and what can be done to prevent it from happening again. Aim to find out not just the immediate causes, but the underlying or root causes. Consider if you’ve contributed to this situation, for example, by setting unrealistic cost targets or turnaround times – conditions that could only be met by use of exploited labour.

If you immediately sever ties, you’re not helping anyone – not the victims, nor the supplier – you’re simply putting your head in the sand and saying, ‘nothing to do with me’.

8. Myth: If you’re doing your due diligence properly, you can claim zero modern slavery in your supply chains

Fact: It’s a sweeping statement, but I believe that any organisation making such claims doesn’t understand the complexities of the challenge. Slavery is prevalent in almost everything we buy.

The Global Modern Slavery Index 2023 reports that of the products at risk of being produced with modern slavery, G20 countries spend the most on electronics, garments, palm oil, solar panels and textiles. Due diligence is about recognising these risks, identifying where those risks may be, and then doing everything you can to mitigate those risks and remediate anyone affected.

Take a look at page 2 of the ETI human rights due diligence framework – it’s a really simple infographic that demonstrates what due diligence is, and the steps you are required to take.

We’ve supported a range of clients with their approach to due diligence in modern slavery, including: Ministry of Justice, Bouygues UK, City of Westminster, TfL, Barratt Developments, Balfour Beatty, Sky, Morgan Sindall, Bam Nuttall, Boroughs of Kensington and Chelsea and South West Railway

Looking for modern slavery and human rights support? Get in touch here.

For more information

EJ Allen
Modern Slavery Consultant

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