We surveyed supply chain and procurement professionals across the UK, to shed light on the impact the Modern Slavery Act has had since its introduction in 2015. Here’s some of the key findings from the Modern Day Slavery Survey Report.
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The Modern Slavery Act, introduced into legislation in 2015, has made businesses think about their procurement process in more detail than ever before.
The role of procurement has now changed too, and professionals play an integral role in sourcing suppliers that follow the law and best practice techniques – creating a more transparent supply chain for their business.
As the Chartered Institute of Procurement and Supply (CIPS) describes, “While modern slavery is illegal in every country in the world, it still occurs in every country in the world.” With legislative risk facing businesses that fall foul of modern slavery, it is vital that procurement professionals fully understand, implement and manage the risk of modern slavery in their supply chain.
To help professionals, CIPS have reinforced their seven stages of the procurement cycle to negate the risk of modern slavery.
You should be looking for supply chain vulnerabilities already. These may be broken down into geographical, sector, or product areas – whatever you believe has the greater risk of employing people under what is deemed modern slavery.
To prioritise risk, you should assess your current and prospective purchases against a number of factors, including level of spend, level of business critical risk, and likelihood of non-compliance against company ethical objectives and the law.
Suppliers deemed to be high risk should develop a map of their supply chains. Using various products on the market to map out your supply chain, you should use this research to understand where the labour-intensive part of your supply chain exists – and ensure good human resource management occurs to negate the risk of modern slavery.
This approach gives greater visibility, beyond the three tiers of your supply chain that you may have already identified. Once identified, contractors need to draft, or review, your social and environmental criteria for appointing suppliers.
Supplier engagement should be used in step three to discover the working standards, best practice, and identified issues of each individual supplier. Once this is done, you should be developing a procurement plan to sustain the quality and price of the product or service you require – without compromising on social and environmental standards.
Buyers should be developing procurement plans with time frames, evaluation criteria, and records of who is responsible internally – to help achieve an ongoing procurement plan that ensures new suppliers meet the new procurement criteria.
Implementing new policies, rules, or procurement processes is always the hardest part for procurement professionals, however this is the only way to ensure full compliance throughout your supply chain.
During this stage, buyers must reinforce to existing suppliers the importance of new environmental and social performance, and should use this performance to assess their contractors in order to meet ethical standards. This should be followed by updating all relevant documents to include questions on new standards – such as on your pre-qualification questionnaire (PQQ), invitation to tender (ITT) and request for quotation (RFQ).
Once PQQs have been submitted, you as the buyer, need to research into any inter-related elements that can negate the chances of modern slavery happening, and improve the overall relationship with your suppliers.
Work should be done to reach out to local organisations, trade unions, and other worker’s groups to identify any potential issues that may occur. This research should also support the written claims of the suppliers surrounding their social and environmental practices. If this is shown to be false on inspection, you know it is time to either help them improve, or to look for other suppliers.
Prices, deadlines, quality, and terms of payment are all standard contractual agreements, but ethical and sustainable clauses must now be added to ensure compliance with modern slavery, as well as other social procedures.
Procurement professionals should go above and beyond to ensure suppliers and contractors thoroughly understand the contents of the contract, obtain any feedback, and more importantly, ensure they stick to the agreed key performance indicators (KPIs).
After adding new clauses in supplier contracts regarding ethical standards, you should be reviewing these as part of your KPI supplier programme on a regular basis. This approach allows you to ensure compliance to agreed contracts and policies, but also allows you to gain a snapshot of which suppliers are struggling to maintain your standards.
Many organisations are now moving towards, what is being called, ‘beyond auditing’ to ensure suppliers are focussed on what is needed to help improve in relation to the new legislation. Training and awareness-raising are typical examples of what you should be doing to aid the education of your suppliers.
The scrutiny that organisations are now facing to improve their supply chain’s conformance to modern slavery is at an all-time high. It is up to procurement professionals, such as yourself, to not only create the ethical policies required for your suppliers to abide by, but also to fundamentally implement this into your processes.
From PQQs to internal KPI monitoring documents, you should integrate ethical standards, such as modern slavery policies, into your processes in order to ensure the uppermost compliance throughout your supply chain.
Discover how UK businesses are rising to the compliance challenge across their supply chain by downloading the inaugural Modern Day Slavery Survey 2017 Report. Featuring key findings from procurement and supply chain professionals such as poor internal policies, failing supply chains, and best practice advice to assure long-term slavery compliance.
A nationwide survey that asked procurement and supply chain experts their thoughts on the impact that the Modern Slavery Act has had on their job, has found some interesting insights.
The survey, which was shared with experts and professionals in 2016, has been compiled into a free downloadable report. Here in this presentation, we outline just some of the key findings that can be explored further in the report.
Download your copy of The Modern Day Slavery Survey 2017 Report and discover what other findings procurement, health and safety and contract managers will be interested in learning about compliance to modern slavery.
The report, which has been endorsed by member of the Parliamentary Select Committee on the Modern Slavery Bill, the Rt Revd Dr Alastair Redfern, is available to download for free.
The Modern Day Slavery Survey 2017 Report, published by compliance specialist Altius, shows that UK businesses need to do more to tackle modern slavery across their supply chains.
The survey of supply chain, procurement and health & safety managers finds that there is a strong desire to break the shackles of modern slavery. But 82 per cent of respondents said that they wanted to see members of the senior leadership team do more to ensure compliance with the Modern Slavery Act.
While 80 per cent of the survey respondents said that their organisations had a Modern Slavery policy, only 60 per cent thought that this had been communicated clearly through the business. And 45 per cent said that they couldn’t see any evidence that the Modern Slavery Act was being adhered to.
The survey also raises questions about effective leadership. One in three of those surveyed admitted that they did not know who had ultimate responsibility for modern slavery compliance in the business.
Only 38% of survey respondents had processes in place to ensure Modern Slavery compliance within their supply chain, with only one-in-four having re-assessed their suppliers since the introduction of the Modern Slavery Act in 2015.
Len Simmons, Chief Operating Officer for Altius, said: “Too often, the responsibility for compliance falls awkwardly between procurement, health and safety and contract managers. It is vital that these parties come together, with support from their senior colleagues, to share the collective responsibility of understanding and implementing effective policies to prevent slave labour.
“Simply having a code of conduct or ethical procurement policy isn’t enough. Businesses need to act on and implement their policies to ensure both they and their suppliers are compliant. The same applies to procurement processes – modern slavery compliance should be ingrained in every audit and questionnaire completed by suppliers.”
In a foreword to the report, The Bishop of Derby, The Rt Revd Dr Alastair Redfern, who is a member of the Parliamentary Select Committee that drafted the Modern Slavery Bill, writes: Modern Slavery legislation recognises the important role of businesses – to ensure that they are not using slave labour, especially in supply chains and through agency workers.”
“This report is a model of how businesses can be encouraged to recognise the realities of the challenge of Modern Slavery, and to identify areas for improvement and the development of good practice.”
Dr. Dave Walsh, Associate Professor at the University of Derby, which collaborated with Altius to produce the report, claims that private sector companies face a ‘hard slog’ to full compliance, not least because modern slavery can be so difficult to identify.
He said: “In contrast to historical slavery systems characterised by whips, chains, and physical imprisonment, modern day slavery is less overt, typically with no obvious visible signs of restraint.”
Altius provides compliance software and management services to help organisations identify and eliminate the risk of modern slavery across their supply chains. To download a full copy of the Modern Day Slavery Survey Report, Click Here.
Named as a top 20 law school by The Guardian, Derby Law School continues to develop responses to modern slavery, including working with the Anti-Slavery Commissioner and the GLA (Gangmasters Licensing Authority) to help combat labour exploitation and upskill the Government’s workforce in understanding Modern Slavery.
Dr. Dave Walsh, Associate Professor in the Psychology of Criminal Investigation and Criminal Justice Law School, gave his view on the role of business in tackling modern slavery in the recently published Modern Day Slavery Report 2017.
“Modern day slavery is akin to the state-sanctioned chattel slavery common in imperial Rome and America in the 1600s. However, in contrast to historical slavery systems characterized by whips, chains, and physical imprisonment, modern day slavery is less overt, typically with no obvious visible signs of restraint.
Over the past few years, prompted in part by the Modern Slavery Act, there have been a number of high profile calls for the UK public to ‘open their eyes and ears’ and assist the authorities in combatting modern slavery.
For businesses, this means that simple auditing of internal and external supply chain processes to ensure modern slavery compliance, is harder than ever before.
What now faces the private sector is a hard slog towards full compliance, but how business confronts the full extent of the challenge remains to
be seen.The University of Derby are responding to these challenges by equipping businesses with the skills to probe labour suppliers through an approved training course, as well as regular seminars to facilitate a better information exchange.
It is activities such as these, alongside this report, that will reflect meaningful engagement by businesses to help fight modern slavery, and avoid their becoming unwitting partners in the trade.”
The introduction of the Modern Slavery Act in 2015 has made UK businesses sit up and take notice of their supply chain more than they have ever done before. Following an extensive research period, the Modern Day Slavery Report compiles the key findings as highlighted by survey respondents.
Discover how UK businesses are rising to the compliance challenge across their supply chains by downloading your free copy of the report today.
A 2016 survey carried out by the Altius team to question procurement professionals around the UK has thrown up some interesting correlations regarding modern slavery.
Despite the majority of respondents being aware of the importance of modern slavery and having a policy in place already, procurement professionals admitted that more needed to be done by their firm to ensure compliance going forward into 2017.
Here’s a look at just five of the key areas that respondents flagged as problem areas, and what actions can be done to ensure they are fully compliant in the future.
While 4 in 5 respondents said their company now has a Modern Slavery Act policy, 45% said that they cannot see evidence of the new policy being adhered to. This includes suppliers and contractors within the respondent’s supply chain.
For firms, simply having a modern slavery policy isn’t enough, especially for the procurement teams. Evidence needs to be gathered as part of supplier assessments and re-assessments to ensure they can show proof of compliance. For example, suppliers could show paperwork relating to the internal procedures they have in place whereby employees can flag up slavery concerns through a whistle-blowing scheme.
Less than 25% of respondents said that they have re-assessed their existing suppliers since the introduction of the Modern Slavery Act in 2015 – almost two years ago. On top of this, 55% admitted that they do not had any modern slavery-specific questions on their supplier assessment questionnaires.
Best practice of supply chain compliance states that existing suppliers should be re-assessed every 12 months at least. While the task can become a burden to procurement and health and safety professionals in-house, business can change considerably in a year, and firms must be aware of these changes in order to be sure their supply chain is fully compliant.
A sore point for survey respondents was the lack of support from their senior team in help dealing with the modern slavery legislation changes. 82% stated they wanted their senior team to do more to enforce compliance throughout the organisation, while only 47% agreed that their senior team fully understood what is deemed ‘illegal’ under the Act.
While procurement teams and health and safety professionals have the ability to manage the risks associated with non-compliance throughout the business and supply chain, ultimately, any blame for falling foul of the new legislation is at the door of the senior management team. Efforts should be made by procurement teams to flag the severe importance of compliance, as well as educating the Managing Director, etc. on what the legislation actually means.
When asked what percentage of their suppliers they believed were compliant to the Act, survey respondents averaged just 30% of their supply chain. One of the main reasons for this result may be down to the amount of time it takes for suppliers to confirm their compliance, thus making procurement teams wary.
47% of respondents confirmed this by saying they were concerned with how long it takes for suppliers to prove compliance. In this situation, procurement teams should pressurise their suppliers more for quicker responses. Automated compliance systems, for example, can help obtain the relevant documents without procurement needing to chase regularly for information.
One of the top challenges respondents said they’d face in 2017 is ‘identifying potential risks in their supply chain’. 41% believe there are hidden risks, however, the same respondents believed that their own procurement processes needs auditing for best practice.
It is clear from these two results that procurement teams need to establish whether their process and documentation is doing enough to collect the information required to pass suppliers as being compliant to modern slavery. Firms should look especially at their re-assessment questionnaires to begin, as well as their on-boarding documents for new suppliers such as PQQs (pre-qualification questionnaires).
Download your copy of The Modern Day Slavery Survey 2017 Report and discover what other areas procurement, health and safety and contract managers believe need action to be compliant to modern slavery.
The report, which has been endorsed by member of the Parliamentary Select Committee on the Modern Slavery Bill, the Rt Revd Dr Alastair Redfern, is available to download for free.
Altius are pleased to launch the inaugural Modern Day Slavery Survey 2017 Report, following the nationwide survey completed by the team last year.
Modern slavery has become a hot topic for procurement and supply chain professionals as firms seek to gain compliance to the new legislation launched by the UK Government back in 2015. As a result, Altius asked for the anonymous opinions of professionals throughout the UK on the impact the new legislation has had.
The report, which has been made available as a free download, shows the fascinating correlations procurement teams are facing throughout different sized companies and sectors they operate in. These correlations include:
The report also contains the survey respondent’s ‘Top 5 Challenges of 2017’ and what they believe the future of modern slavery compliance will look like.
Download The Modern Day Slavery Survey Report
The report has been compiled with leading modern slavery experts, including educational establishment, Derby Law School, and the Rt Revd Dr Alastair Redfern. Speaking on the importance of this report, Dr Redfern, a member of the Parliamentary Select Committee who drafted the Modern Slavery Bill, said:
“This report is a model of how businesses can be encouraged to recognise the realities of the challenge of Modern Slavery, and to identify areas for improvement and the development of good practice. Such responses will mitigate risk, improve standards and help to eliminate the presence of slavery in supply chains.”
The introduction of the Modern Slavery Act in 2015 has made UK companies sit up and take notice of their supply chain more than they ever have done before. Companies have been quick to assess their supply chain, but also to ensure that they are adhering to the updated legislation with a code of conduct and an ethical procurement policy.
An ethical procurement policy must make it clear to suppliers that compliance with requirements related to the Code of Conduct is mandatory. This requirement applies not only to existing suppliers but also to supplier selection and retention. This policy will be useful to set out what the process will be when breaches are found.
A report by modern slavery charity, Walk Free Foundation, alongside the Chartered Institute of Procurement & Supply (CIPS), sheds light on the fundamentals that any ethical procurement policy should include. For companies who have yet to create a modern slavery policy, or those who would like to check the validity of their existing policy, here’s the four key areas the policy should include.
Through purchasing decisions, companies have the capacity to improve the working conditions of those employed by exploitative suppliers whilst rewarding those who treat workers with dignity and respect. The report, Tackling Modern Slavery In Supply Chains, says:
“Many buyers are developing programs that reward suppliers who demonstrate particularly strong social performance. The top suppliers get preferred supplier status and are given priority for new business.”
For suppliers that fail to adhere to the policy, or provide misleading statements, punitive measures could be added to your company policy. Training and guidance should be used to help suppliers and contractors understand modern slavery – only as a last resort should you cease to work with a supplier due to their human right violations.
An ethical procurement policy needs implementing, and not just putting on the shelf to collect dust. The key standards you’ve highlighted in your policy should flow through all aspects of your company’s supplier sourcing and management.
These key standards, according to the report by Walk Free Foundation, are:
With regard to sourcing processes, your Code of Conduct requirements should also be built into the Request for Tender (RFT), pre-qualification questionnaire (PQQ) and other application documents you use.
It is important to ensure that these key standards then flow through all aspects of supplier sourcing and management including; your supplier contracts, tender and purchasing processes, auditing and compliance actions, and performance standards for procurement staff too.
Another important part of a procurement policy is to set job performance objectives and targets for procurement professionals in your business, with modern day slavery in mind.
Traditional procurement focused on purchase price, safety and technical capabilities and procurement professionals are evaluated based on acquiring the best product for the best price. As the report by Walk Free Foundation says, this focus needs to change.
“Today, procurement professionals have a critical role to play in preventing modern slavery in supply chains by selecting new suppliers that have properly enforced policies and procedures against slavery and forced labour.”
By keeping ethical considerations at the forefront of purchasing decisions, procurement professionals can promote workers’ rights and decent working conditions. It is imperative that professionals are evaluated based on the successful acquisition of goods and services that are produced using ethical social criteria, as well as the traditional objectives around price and quality.
Once your ethical procurement policy framework is in place, this should become the foundation on which the company builds strategy for engagement with internal and external stakeholders and suppliers.
Sharing and communicating the Code of Conduct on forced labour and modern slavery is integral to its implementation. Staff across the company will need to familiarise themselves with its vision and principles.
Of course, the most important staff members that need to fully understand the policy is your procurement and supplier management staff. But your communication shouldn’t be limited to inside the business. As the report suggests, your communication strategy should:
Rightly so, the government’s intervention on modern day slavery has meant that the need for clarity in your supply chain has never been so important. While creating an ethical procurement policy isn’t a taxing task, implementing and getting it understood by procurement staff and suppliers is the hardest part.
Discover how UK businesses are rising to the compliance challenge across their supply chain by downloading the inaugural Modern Day Slavery Survey 2017 Report. Featuring key findings from procurement and supply chain professionals such as poor internal policies, failing supply chains, and best practice advice to assure long-term slavery compliance.
Businesses that outsource work to contractors and sub-contractors are invited to a free seminar on Wednesday 30 November to find out how to de-risk their operations in the light of new health and safety and modern slavery laws.
Industry expert Peter Hall, Technical Director of the International Institute of Risk and Safety Management (IIRSM), is the keynote speaker at the seminar. He will advise on leadership in contractor risk management.
The seminar ‘Be prepared: Updated HSE and Modern Slavery Act guidelines explained’ will be hosted by compliance and supplier management specialists Altius VA, in partnership with Howes Percival LLP.
Solicitors Alan Milliband and Clare Leverton of Howes Percival will brief delegates on the latest health and safety laws, particularly on the new sentencing guidelines, which have introduced stiffer penalties. They will also explain business requirements under the new Modern Slavery Act, which places an onus on large organisations to introduce checks across their supply chain.
Gary Plant and Adam Gomes of Altius VA will explain how to build a fully compliant supply chain using modern software systems for contractor and sub contractor assessment and accreditation.
They will be joined by Jeremy Peat of Totectors, who will brief the audience on how to meet their health and safety duties relating to the use of personal protective equipment (PPE) in industry.
Gary Plant, Managing Director of Altius VA, said:
“Stricter health and safety laws and increasing regulation, such as The Modern Slavery Act, mean that organisations need to get a firm grip on compliance. It is critical for organisations to scrutinise their health and safety policies and ensure that risk is assessed across the entire supply chain.”
“Our seminar will brief organisations on the latest legal requirements and present effective strategies for managing and minimising risk – using robust and agile compliance procedures.”
The free seminar will take place on Wednesday 30 November (9:30am – 4pm) at Howes Percival LLP in Leicester. Register for the free seminar here.
The Modern Day Slavery Act implemented by the UK Government in 2015 was welcome news as global leaders fight to out-rule modern slavery. For business here in the UK since the Act was introduced, it has been a learning curve to first understand what is now required to meet legislation, and second to implement a code of conduct and procurement policy that safeguards the future of the business.
Within this learning curve, the nuances of what to look out for in susceptible supply chains have been identified by international groups and charities to help businesses stay compliant. The International Labour Organisation (ILO) has identified a number of indicators that constitute forced labour and all of which are covered in the Modern Slavery Act 2015. This includes:
While most of the above criteria is self-explanatory, thus making it easier to communicate the Act with your procurement team and suppliers, debt bondage is a relatively new phrase to the industry.
To aid the understanding of debt bondage, the following description from charity Walk Free Foundation should help to explain it further:
“Debt bondage is a worker pledging their labour or the labour of others under their control as security for a debt; when either the real value of the work undertaken is never applied to repayment of the debt, or the length and nature of the work that has to be undertaken is never fully defined or limited.”
To further explain Debt Bondage, the Walk Free Foundation in their report, Tackling Modern Day Slavery in Supply Chains, they used a real case study to explain how this practice works.
In South Asia, where caste-based stratifications still dominate the social landscape, many lower caste families working in the brick kilns are plagued for years, sometimes generations, by languishing debt.
“The initial debt is often incurred through loans from subcontractors which can never be repaid. The debt is then assigned to the entire family and is not nullified even in death. This means children are forced to work or take on the mounting debts of their deceased parents. Debt bondage subjugates entire families to inescapable cycles of poverty and a life of work in the brick kilns across the region.”
This atrocious way of employing workers, of course, needs stamping out. But identifying whether this practice is already in your supply chain can be a hard task. To help businesses out-rule debt bondage and indeed any of the offences under the Modern Day Slavery Act, Corporate Responsibility (CORE) have outlined the key requirements businesses should have to protect themselves, and individuals that may be subjected to modern slavery in their supply chain.
As a basic foundation, businesses should be complying with UN Guiding Principles that clearly the state that policies and processes should be in place to ensure human rights. On top of this, businesses need to map existing policies and codes of conduct and identify the coverage of risks related to modern slavery.
Whilst not every company may not have a specific policy on human rights or slavery, you are likely to have at least some policies in place which these relate to. Ensure the most vulnerable areas of your supply chain include policies where applicable on migrant labour, child labour and child protection policies.
As a minimum, businesses should adopt procedures and policies that cover the fundamentals as set out by the ILO and Rights at Work scheme. This includes respecting the freedom rights of individuals and allowing them to move in and out of employment freely, without the threat of a penalty.
Your policies should also include information on the intolerance of abusive recruitment practices. These not only increase worker vulnerability, but they have been found to lead to debt bondage and forced labour.
Policies should then be made publicly available and given to suppliers and contractors. This should be swiftly followed by follow-up communication to ensure your supply chain understands the policies, and that they are adhering to them.
The consequences your businesses supply chain could face, if they don’t comply, should be made very clear in your policies. The seriousness of losing a contract from your business, shows the importance of adhering to policy guidelines.
Following the implementation of the policies, procurement teams should be integrating issues the Modern Day Slavery Act holistically into their working practices. As well as asking new suppliers and contractors to comply to your modern day slavery policies, application forms such as pre-qualification questionnaires (PQQs), and updated information questionnaires from existing suppliers, should include questions on modern slavery.
For those suppliers or procurement professionals that have identified a vulnerability in your supply chain, a whistleblowing and complaints procedure should be put in place, and put in your policy too.
This combination of contingency and crisis policies and procedures, as highlighted above, can help to negate the risk of you and your supply chain falling foul of the Modern Day Slavery Act.
Debt bondage, as one of part of the act, is something that we all agree shouldn’t have a place in our supply chains. By implementing this best practice around modern slavery policies, you can ensure that debt bondage is a thing of the past – and your business is assured of legislation compliance too.
Discover how UK businesses are rising to the compliance challenge across their supply chain by downloading the inaugural Modern Day Slavery Survey 2017 Report. Featuring key findings from procurement and supply chain professionals such as poor internal policies, failing supply chains, and best practice advice to assure long-term slavery compliance.
