The beginners guide to addressing modern slavery risks

With an estimated 50 million people living in slavery across the world, modern slavery is a huge issue, and as an organisation it can be difficult to know where to begin in addressing the problem.

Organisations can cause, contribute or be linked to modern slavery practices. Regardless of the type or size, all organisations have a responsibility to understand and address modern slavery within their own organisation and supply chains.

Modern slavery practices can occur in any country or industry sector. However, there are some factors that can increase the risk of modern slavery, such as geography (check out the Global Slavery Index), vulnerabilities (such as migrant workers, gender, seasonal workers) and business models (for example labour market structures or long and complex supply chains).

There are many drivers for an organisation to identify and respond to modern slavery risks, whether it is complying with legislation, responding to investor and customer expectations, or whether it is just ‘the right thing to do’. Whatever your organisations motivations, here is your beginners guide on where to begin.

Identify

Risk identification flags where potential modern slavery exists within operations and supply chains.

A typical way to assess risks is through a heat mapping process.

• This assessment can be done on different operational or supply chain areas, for instance by business unit, spend category, product or supplier level.
• Risk factors should be taken into account when identifying risks. Consider within these operational or supply chain areas which factors intersect. Does it involve vulnerable populations, is it sourced from a high risk geography, is it part of a high risk business model or sector?
• Risk analysis also involves a detailed consideration of uncertainties, risk sources, business relationships, supply chain, consequences, likelihood, events, scenarios, controls and their effectiveness.
• Finally, this process should be done through consultation with multiple stakeholders, this aims to bring together different areas of expertise, taking into account different views, facilitating risk oversight and decision making and building a sense of inclusiveness and ownership of the risk.

Output – risk rating for each operational or supply chain areas you have assessed and recorded reasoning behind the risk categorisation.

Prioritise

Once you have an overview of your risks, you should prioritise, as pragmatically it is impossible to address everything all at once.

When prioritising modern slavery risks, the saliency of the risk should be determined. Saliency can be understood by considering:

• Scale – how serious would an occurrence be?
• Scope – how extensive would an occurrence be?
• Remediability – how effective would remediation be?

In the instance of remediability, this is where considerations of your organisations resources, values and leverage should be considered. Simply think – where can you have the most impact to address your modern slavery risks?

Output – a list of prioritised areas to focus your action to address modern slavery.

Mitigate

Now that you have a list of prioritised risks, you should develop strategies to address and mitigate these risks over time. These strategies are underpinned by a number of enabling activities. Without these enablers, the strategies are often not effective.

• Commitment from leadership
• Clear roles, responsibilities and accountabilities
• Training and awareness
• Stakeholder engagement
• Responsible employment processes
• Sustainable procurement processes
• Remediation and grievance procedures

All of these enablers are detailed in the new and free British Standard BS25700 – Organisational responses to modern slavery – Guidance.

Output – strategies, with allocated resources, to address prioritised modern slavery risks.

Monitor & report

Performance and evaluation helps to improve the quality and effectiveness of modern slavery actions. Monitoring of actions, risks and incidences should be done on an ongoing basis. Metrics should be put in place to monitor this. For example:

• Number of employees trained
• Number of incidents reported and investigated
• Partnerships in place
• Percentage of high-risk suppliers with modern slavery clauses

Build reporting and reviews into existing governance models e.g. internal audits, committees, board meetings. If a legal requirement, progress should be reported in your annual transparency statement, otherwise it is good to report and be transparent to keep stakeholders aware of progress.

Output – modern slavery governance process in place, with regular monitoring and reporting on progress.

Collaborate

On all the above and more, collaboration is key. Organisations often have similarities in their business models and supply chains and therefore share many risks and consequently opportunities to create impact. A few examples of collaborate spaces are:

• Supply Chain Sustainability School’s Modern Slavery Group
• Slave Free Alliance
• Rail Safety and Standards Board
• Solar Stewardship Initiative

For more information or to explore how Action Sustainability can support your organisation, please contact our team.