Enhancing Social Audits in Modern Slavery Due Diligence April 2024

Social audits are a vital component of modern slavery due diligence processes as they contribute to identifying, preventing, mitigating, and addressing adverse impacts within organisations and their business associates. Aligned with the UN Guiding Principles on Human Rights and Business, due diligence is defined as: “Ongoing risk management process aimed at identifying, preventing, mitigating, and accounting for how adverse impacts are addressed in the organisation and its business associates.”

While social audits can foster collaboration and relationship-building, it is crucial to recognise that auditing alone cannot guarantee the eradication of forced labour from supply chains.

1. Engage a Local Auditor with Industry Experience:

When selecting an auditor, opt for someone with industry-specific experience and local knowledge. Choosing an auditor from the region or area where the audit will take place eliminates the need for translators and ensures a better understanding of on-the-ground issues and contextual factors. A local auditor can also provide unique insights that may go beyond what is considered typical.

2. Collaborate with NGOs or Smaller Audit Companies:

Consider engaging an auditor from an NGO or a smaller audit company. Larger audit firms often subcontract audits, introducing additional layers of complexity. By working directly with auditors from NGOs or smaller firms, you can establish a closer relationship and promote greater independence throughout the auditing process.

3. Conduct Unannounced Audits:

To minimise the opportunity for hiding or fixing issues before the audit, conduct unannounced audits whenever possible. Although unannounced audits are not foolproof, as delay tactics can still be employed (e.g., triggering a fire alarm), they significantly reduce the preparation time for non-compliant practices.

4. Amplify Worker Voice:

Listening to the voices of workers is essential to gain insights into their experiences and identify potential labour rights violations. Conduct interviews with workers, ideally on a one-to-one basis, and strive to gather a substantial quantity of interviews, exceeding the minimum requirements set by industry standards. Technology, such as mobile devices, can be utilised to collect worker voice insights. However, ensure that the use of mobiles is not prohibited on the audit site. In cases where mobile use is restricted, provide workers with cards to take home and encourage them to share their perspectives outside the workplace. It is crucial to make these materials available in multiple languages to facilitate communication.

5. Involve the Client in the Audit Process:

Bringing the client along on the audit journey can provide them with firsthand insights into the conditions and challenges faced by workers. This first-hand experience can enhance their understanding and commitment to remediating any identified issues. Moreover, the client’s involvement can increase their leverage to drive change throughout the supply chain.

When planning a social audit as part of modern slavery due diligence, considering these crucial factors can significantly enhance the effectiveness and impact of the audit. By engaging local auditors, valuing worker voices, conducting unannounced audits, collaborating with NGOs or smaller firms, and involving the client, organisations can take proactive steps to address labour rights issues and foster sustainable supply chains.

If you’re interested in combatting modern slavery within your organisation or supply chain, get in touch with us today.