It’s been more than four years since The Modern Slavery Act (2015) provided some much-needed tools for fighting modern slavery here in the UK…

Unfortunately, over 200 years on from the abolition of the slave trade in Britain, the gaps in our modern-day legislation are starting to show – and mean that large numbers of workers both here and abroad continue to suffer dangerous and dehumanising conditions. Despite the UK’s efforts to take the lead in stamping out modern slavery, the Global Slavery Index estimates there are currently 16 million victims of forced labour in the private sector.¹

While most UK businesses have been quick to recognise their responsibility and keen to eradicate slavery, compliance with modern slavery legislation isn’t always easy, particularly where intricate supply chains make data gathering difficult. For those businesses who have let anti-slavery measures slip down the agenda or suspect that their supply chain needs deeper scrutiny, it may be time to strengthen strategies. Modern slavery is back in the spotlight for 2019, with more cases reaching the courts and the press, and anticipated new legislation which could increase both the burden of compliance and the risk of inaction.

The business risk of modern slavery

Although a particular issue in construction, agriculture and anywhere that high numbers of short-term contractors and second tier suppliers are used, modern slavery is something businesses from all sectors should confront without delay. Failure to act is no longer a purely ethical concern: a recent review of the 2015 legislation, growing public awareness thanks to the action of groups including Business & Human Rights Resource Centre, ShareAction, Global Witness and CORE, and a 2019 Supreme Court ruling (Vedanta Resources Plc v Lungowe²) which has broadened the duty of care imposed on businesses, have all combined to create an environment in which a business could be putting its operations, investment and reputation at risk if it fails to take modern slavery seriously.

Unfortunately, difficulties associated with ensuring compliance across complex supply chains, particularly where pockets of low visibility or limited leverage exist, has meant that even some leading global companies have failed to prioritise good practice. A recent report by the Business & Human Rights Resource Centre (BHRRC)³ has revealed that the modern slavery transparency statements provided by many FTSE100 companies were “weak… offering little or no information (on the six reporting areas defined by the 2015 Act)… changed very little from year to year and did not show progress on understanding their modern slavery risks”. The BHRRC believes that the Modern Slavery Act 2015 failed to deliver the transformational change it promised. It is just one of many voices now calling for major reform of UK law.

Recommended changes will bring new responsibilities

So, what is likely to change and how will it affect UK businesses? Australia’s 2018 Modern Slavery Act, which came into force on January 1^st 2019, has gone further than UK law by defining mandatory reporting criteria. It is expected that the UK will want to stay ahead of global legislation; making mandatory reporting requirements highly likely when the Modern Slavery Act is updated. While this was not an explicit recommendation of the Independent Review of the 2015 Modern Slavery Act⁵, mandatory due diligence is high on the priority list for many key stakeholders who believe that legislation should be doing more to protect vulnerable workers. Additionally, during April 2019 a group of UK civil rights organisations including ClientEarth, Amnesty International and Unison, called for a mandatory human rights and due diligence law for all UK companies⁴.

The overriding message to businesses is that those already included within existing legislation would be wise to start preparing for more stringent reporting obligations in the imminent future; while those who fall outside the scope of the 2015 Act should be aware that they too may soon be held accountable for ‘irresponsible corporate practices’.

One explicit recommendation which did come out of the Independent Review was that businesses be made responsible for the ‘entirety’ of their supply chain. Other notable recommendations include making non-compliant companies ineligible to bid for public procurement contracts and – significantly – making ‘failure to fulfil modern slavery statement reporting requirements or to act when instances of slavery are found’, an offence under the Company Directors Disqualification Act 1986⁵. Put simply, this would mean that a named, designated board member would be accountable for their organisation’s modern slavery statement and actions. In the future, failure to act will therefore be likely to bring consequences for businesses and the individuals who lead them.

Ensuring compliance

A business is already captured within the criteria for the Modern Slavery Act 2015 if it supplies goods and/or services, has an annual turnover of £36m or more and carries on a business or part of a business in the UK. These businesses are required to produce a slavery and human trafficking statement for each financial year. They must set out ‘the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business’. If no steps have been taken, transparency requires that this be stated, although recommendations for reform include prohibiting a statement of ‘no steps’ and requiring that action be taken.

Ensuring modern slavery compliance can be a time-consuming task and is unfortunately one that often falls between departments, with no one team or individual taking ownership. However, with accountability looking set to increase, developing a clear compliance process is more important than ever before. Wherever a business sits in the supply chain, online data systems that are easily updatable are a must, while businesses with a turnover of more than £36m need seamless systems for requesting information from suppliers; one which goes further than the PQQ data requirements and which is repeated on an annual basis. These organisations should also seek evidence of procedures being followed, communicating regularly with all participants in the supply chain and using desk-top and on-site audits to ensure that suppliers are acting appropriately. Due diligence is the only way to protect your business from the risks posed by modern slavery.

For practical advice on putting greater control around your supply chain when it comes to modern slavery, speak to our compliance experts or download our guide for more information.

1. https://www.globalslaveryindex.org

2. In April 2019, the Supreme Court in Vedanta Resources Plc v Lungowe determined that a UK-domiciled parent company may owe a duty of care to third parties affected by operations of its Zambian copper mine subsidiary. Vedanta is the holding company of KCM, which is the owner-operator of the Nchanga copper mine. https://www.whitecase.com/sites/whitecase/files/files/download/publications/supreme-court-finds-that-uk-domiciled-parent-company-may-owe-duty-of-care-to-third-parties-for-the-acts-of-its-foreign-subsidiaries.pdf

3. FTSE100 and the Modern Slavery Act: From Disclosure to Action https://www.business-humanrights.org/sites/default/files/FTSE%20100%20Briefing%202018.pdf

4. https://corporate-responsibility.org/wp-content/uploads/2019/04/190417_UK-mHRDD-campaign-statement_FINAL-with-logos.pdf

5.https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/803406/Independent_review_of_the_Modern_Slavery_Act_-_final_report.pdf

Managing your supply chain can be complex and when you’re busy thinking about logistics, procurement, IT security and a host of other requirements, managing supplier compliance can fall down your list of priorities…

But as it’s your organisation’s responsibility to ensure every contractor working for you is compliant – and your reputation that’s at risk if something goes wrong – it’s crucial to make sure that everyone understands what’s required of them and can meet compliance standards.

Here are our top tips for securing supplier compliance from the start of a project:

Gather Relevant Information

Every project is different, and every supplier will have their own unique capabilities. To find the suppliers that are capable of carrying out a specific job successfully, you need to be clear on the information you need from them.

It can be tempting to ask as many questions as possible to all your suppliers, but you should only ask for the information you really need. If a supplier will never need to work at height while on your project, for example, then asking them whether they’re registered to work at heights is unnecessary. Being clear on what’s required should make it easier for suppliers to demonstrate their capabilities.

Verification is Key

Supplier assessment, or onboarding, is critical to ensure that the capabilities suppliers claim to have are valid, but it can be a time-consuming process. Before any work begins, you must check your supplier’s standards and verify that they have the insurance and certifications they need to meet your health and safety requirements.

A one-off check of suppliers’ credentials isn’t enough either – you must make regular checks to make sure that they’re compliant for the duration of the project. If a certificate expires or their insurance lapses while they’re on site, you could be liable.

Be Clear on Authorisation

When you approve a supplier to deliver work for your company, being specific on what they are authorised to do can make a real difference to your own team and to your suppliers.

Make sure everyone knows which suppliers are approved for which jobs – investing in good software can help you to distribute this information throughout your organisation and reduce admin time. Integrating supplier compliance information into your procurement and ordering systems can also streamline the process and ensure that non-approved suppliers aren’t used. You should also tell suppliers exactly what they’re approved for, as this should give them a sense of pride in their status and motivate them to maintain it.

Compliance Doesn’t Have to be Complex

When you’re trying to get a project off the ground quickly, having a simple way to see which suppliers are compliant with your requirements can significantly reduce your admin time. With Altius’s Exigo platform, you can develop a set of compliance questions that are tailored to your unique needs, so it’s clear to suppliers what is required of them.

Once you’ve chosen a supplier, you can also use Exigo to get a real-time view of their current compliance status, so you can rest assured that you’re not exposed to risk at any point in your project.

*If you think streamlining your supplier authorisation process could benefit your organisation, get in touch to find out more.

The retail industry is the largest private sector employer in the UK, providing jobs for around 3 million people across the UK…

As you would expect from a sector of such proportions and encompassing such a diverse range of businesses, the daily tasks completed by employees are extremely varied. Some will be members of a customer service team who spend most of their time on the shop floor, while others will have manual or inventory duties in a stock room or warehouse setting; for some, there may be only limited movement away from a checkout, while others will have days that consist mostly of manual lifting and carrying. The hazards of a retail workplace will depend on a broad range of factors including the size of the team, the different areas that make up the working environment, and the products stored and sold, so devising an effective health and safety plan may seem tricky at first – but it’s vital that employers prioritise safe working.

Health and safety to suit all sizes

The legal duty of retail employers, as with other types of employer, is covered by the Health and Safety at Work Act 1974. It requires employers to ensure, so far as is reasonably practicable, the health, safety and welfare of employees. With such a broad duty to fulfil, retailers could be forgiven for feeling like protecting their employees is a near impossible task – but it’s important to remember that the legal requirements can be broken down into assessment and control of risk. Many of the risks associated with retail can be eliminated or reduced through good communication, effective housekeeping, common sense procedures and basic training. The most important thing is that retailers recognise their duty and act on it, rather than assuming that low risk probably means no risk.

While retail hazards may seem relatively few compared to manufacturing or construction, in a busy retail environment it can be easy for smaller dangers to be overlooked. Potential risks like blocked exits, poor product storage methods and lack of manual handling training can lead to accident and injury if not controlled. This can reduce productivity, increase illness absence, and lead to unnecessary costs for employers. It’s also vital that employers recognise that the regulation governing the use of work equipment and hand tools does apply to retail workers operating electronic point of sale machines to complete transactions, climbing on stools and step ladders to reach shelves or using knife blades to open boxes, as harmless as these activities may seem.

In recognition of the different challenges retailers may face, the Health and Safety Executive (HSE) has made it easier for small retail businesses to evaluate the dangers employees are exposed to by creating a shop risk assessment tool.

The tool helps employers in lower-risk retail environments to create a tailored assessment, focusing on the hazards to their workforce and how they might be addressed. It covers the most common causes of injury in the retail workplace, such as tripping hazards and falling objects as well as repetitive strain injury and musculoskeletal injury. It also asks retail employers to consider workplace transport, the potential for high or low temperatures, the use of electrical equipment, timing of breaks and the presence of any flammable stock.

For larger retail organisations, the emphasis is on establishing best practice across all sites. This can be problematic where premises are spread over different local authority areas but has been made simpler by the Better Regulation Delivery Office’s (BRDO) Primary Authority scheme. The scheme gives a business the right to form a statutory partnership with a single local authority. This helps to ensure that a consistent approach to health and safety regulation can be ensured across the entire business.

The ongoing problem of trips and slips

Trips and slips remain the single most common cause of major injury in the retail workplace. Most accidents occur when spills are not cleaned up or when floors remain wet and slippery after cleaning. For a large retailer, a single slip could cost £15K or more. The HSE provides special guidelines* for preventing slips and trips in retail.

The dangers of violence and lone working

Violence against retail workers is unfortunately a growing problem and one which many employers are obliged to factor into their health and safety assessments. The British Retail Consortium (BRC) reports** that 13 retail workers are injured every single day and that the rate of reported violence with injury has doubled over a year to 6 per 1,000 workers. This is not only a concerning statistic, it also highlights the additional cost that crime creates for retail businesses, who must also deal with customer theft. In fact, the BRC estimates that crime is now costing the retail sector more than £700 million each year.

For retailers, tackling the risk of violence is a duty under the Health and Safety at Work Act in the same way as dealing with any other possible cause of harm in the workplace. Whether physical or verbal, violence can have a long-term impact on both employees and the businesses they work for, causing issues such as high staff turnover, work-related stress, and a damaged business reputation – and risks are often higher in licensed premises, where there are younger workers or where workers spend time alone on the premises, particularly at night.

Violence against workers can be another unpredictable area where employers may feel as if the protection they can provide is limited. However, there are clear guidelines available and sensible steps which can be taken to lessen the risk of violence. These include the provision of conflict management training for employees, thinking about shift patterns to avoid lone working at times of highest risk and installing extra security measures where appropriate.

Reporting of in-store is an important of health and safety within the retail environment. To learn more about how we helped Debenhams deploy a bespoke in-store incident reporting system, read our case study here.

*To read the HSE special guidelines for preventing slips and trips in retail, click here.

**Download the full 2017 retail crime survey from The British Retail Consortium (BRC) here.

The UK’s rail network has a safety track record to be proud of…

The latest annual report from the Rail Safety and Standards Board (RSSB) tells us that Britain’s railways remain the safest of the top 10 biggest railway systems in the EU. While this is brilliant news, the rail industry can never afford to be complacent on health and safety. There is always room for improvement and even one incident can change the shape of things dramatically. So, while Network Rail report that track worker safety has improved in recent years: there have been six fatalities in the past nine years compared to 25 in the previous 9, it’s crucial to remember that even one death is too many. Every worker has the right to return home safely and without injury after their shift ends.

High numbers of near-misses

Despite regulation by the Office of Rail and Road (ORR) and the standards set by the RSSB, Simon French, chief inspector for the government’s Rail Accident Investigation Branch (RAIB), has issued a spate of warnings recently that the rail industry is failing to tackle some of its important safety issues effectively. This includes high number of ‘close calls’ and workers often having no clarity on who is in charge on site.

The warnings come after the death of a rail worker in Purley, South London during 2018 and unfortunately were not heeded in time to prevent the deaths of two more rail workers in South Wales during June 2019. In this latter case, it is thought that the workers were wearing ear defenders and may not have heard the approach of the passenger train which caused their deaths. The incidents were both avoidable through straightforward health and safety measures and employer Network Rail has now responded to pressure from ORR and union bodies to step up their efforts to safeguard the people who maintain and repair their tracks.

Network Rail has pledged investment of £70m in a new safety initiative and task force, which will accelerate its existing Near Miss Reduction Programme and attempt to eliminate fatalities for those working on or near their track system. The task force will be responsible for a broad range of new measures, including the implementation of advancements in technology and warning systems for safer trackside working, better monitoring of contractor training and competencies, a ‘procuring for safety’ programme to encourage and reward contractors for safe practices, a medical standards project, and better risk management processes. There will also be new measures for managing fatigue and improving mental wellbeing both major contributors to raised overall health and safety standards in the workplace.

It is thought that the South London worker who lost their life was not only put at risk by the failure of a fellow contractor to arrive for work but was also on a zero-hours contract and likely to be suffering from fatigue – and the topic has also received particular attention in the RSSB’s report. The investigation is ongoing, but one thing is clear: while fatalities are falling, the number of near misses remains unacceptably high. It’s time for employers and employees across the sector to take a fresh look at their own health and safety measures, particularly where there are high number of contractors and it may be more difficult to have a clear oversight of their skills and training.

Taking action

As in every UK employment scenario, rail industry employers have a duty to their employees under the Health and Safety at Work Act 1974. Failure to fulfil that duty can not only have negative impact on productivity, profitability and reputation; it can also mean that employers lose valuable team members and face costly penalties. While the duty of a rail business as an employer is the same as in any other industry, the high-risk nature of railways work means that it requires specialised enforcement focus. This duty is now separately overseen by the ORR rather than the Health and Safety Executive (HSE), thanks to powers handed over by the Health and Safety (Enforcing Authority for Railways and Other Guided Transport Systems) Regulations 2006 (EARR). Since taking responsibility back in 2006, the ORR have issued penalties ranging between £65K and £4m for breaches of health and safety regulations.

According to the ORR, one regularly occurring factor when accidents occur and the employer is found responsible, is that inadequate measures had been taken to plan safe systems of work or properly assess risk*. Thankfully, this is one area in which help is available to take effective action. We can help you review and revise current processes to ensure they are carefully aligned with SSIP, as well as providing unique insights into the health and safety culture that exists right across your organisation. Yours is a complex business and you want to make sure the people you are responsible for are fully skilled, properly trained and safely managed.  We can make safe procurement easier, reducing the load on your internal teams and keeping paperwork to a minimum.

*For more information on health and safety from the ORR click here.

When you’re searching for new suppliers, you want to find out whether or not they can meet your requirements sooner rather than later – and that’s where your pre-qualification questionnaire can really make a difference…

Many buyers rely on the standardised PQQ format provided by PAS 91, which was specifically designed to reduce the time both buyers and suppliers spend on the prequalification process. But every organisation has its own unique requirements for suppliers, which is leading increasing numbers of buyers to adapt PQQ templates to suit their organisation. This way, they can find out which suppliers have everything they’re looking for from the outset.

With this in mind, here are our top tips for tailoring your PQQ to your organisation:

Start with the basics

There are some questions that you will need to ask of our suppliers, regardless of your unique needs or the particular project they will be working on. You will need to ask them for details of their financial status, for example, and all of the basic information about their business, such as their address and VAT number. Refer to the question set used in PAS 91 to ensure that you include all of the key information you need from all suppliers.

Protect your organisation

If an issue occurs on your site, your organisation’s reputation could be damaged – so make sure you only work with reputable suppliers by checking their credentials at the pre-qualification stage. Asking to see any data or certifications they have around employer liability, public liability and their professional indemnity insurance is a good first step. You should also ensure that they operate fair working practices by including questions around their anti-slavery policies and their compliance with equality legislation.

Secure your site

While many health and safety questions, such as asking for a copy of a supplier’s health and safety policy, will be included in your PQQ as standard, asking a few extra questions can make a real difference to the safety of your staff and site. If there’s potential for contractors to be working around children, for example, you could ask for all workers to pass DBS checks before coming on site. You may also seek contractors that are certified or are willing to undertake training on safeguarding vulnerable adults, if this is a risk for your business.

Consider your priorities

When personalising your PQQ, you can also add in questions designed to discover which suppliers are most closely aligned to your organisation’s core objectives and values. If you’re determined to give back to the local community, for example, you could ask contractors whether they’re willing to commit to employing local labour. If you’re known for your sustainable approach, on the other hand, you could ask suppliers what processes they have in place to minimise their impact on the environment.

Take a tailored approach

If you’re interested in customising your PQQ to your organisation’s unique requirements, the Altius platform can be incredibly useful. You can develop your own set of compliance questions on the platform, so you can quickly and easily identify which suppliers are right for your project.

To find out more about how Altius’s software can support you throughout the supplier authorisation process, click here.

According to global retail consultancy FITCH, “retail will change more in the next five years than the past 50”…

They believe that the outlets of tomorrow are being shaped not only by economic, product and industry trends, but also by shopper behaviours, needs and demands. Add to that an increasing focus on operating fairly and compliantly and it’s clear that now more than ever, retailers rely on a robust, responsive and progressive supply chain to ensure they are equipped to meet the demands of an ever-demanding public.

Generous brands

As shoppers become more aware of the role of ethics in the retail space, they are also more ready to scrutinise the businesses from which they are buying – and this extends to their supply chain. A compelling 78% of consumers say they would recommend a company they believe to be ethical, putting greater emphasis on retailers to instil appropriate values and standards throughout their supplier network, ensuring that any efforts to maintain a ‘generous’ reputation truly stand the red face test.

Compliance solutions, such as the Altius platform, make a significant difference in turning an ethical ambition into a reality. The platform can be tailored to capture individual organisational requirements, whether that’s specific environmental procedures or evidence of an anti-modern slavery policy. Our compliance team go on to assess supplier documentation in detail to make sure that each potential partner adheres to retailers’ exacting requirements, giving peace of mind that they’ll only work with suppliers that uphold their standards.

Giving your business the best growth opportunities

Reputation is everything, particularly in the retail market where corporate values can really make the difference for retailers looking to differentiate from their competition. By demonstrating a commitment to the values that are important to retailers, your business too can stand out from the crowd. With the retail environment undergoing so much change – and so quickly – suppliers that can demonstrate a willingness to progress, adapt and support retailers are the ones that stand to thrive. In a world where consumers demand more, to be adaptable is to survive. Responding quickly to new requirements ensures that you remain in the pool of trusted suppliers, enabling retailers to operate with peace of mind that they are catering appropriately for the needs of their customers, stakeholders and shareholders.

As Mitchell Goosen, Head of Programme Office for Property at M&S, puts it:

“The [Altius] platform ensures our supply base are competent and fit-for-purpose; this married with the platform’s ability to evolve with ever changing business needs is integral to achieving the fast pace of change required to compete in the rapidly shifting retail environment. Altius is the essential cog in maintaining legislative compliance across an expansive M&S supply chain.”

As the world of retail evolves, it’s likely that retailers will look to suppliers more than ever before to provide effective support – whether that’s in proving their generosity, shortening their fulfilment timescales, finding new ways to engage consumers or adhering to new regulations.

To learn more about the key trends facing the retail sector, download our report. And to learn more about how your business could better prepare itself to support the sector, providing new opportunities to work with some of the UK’s biggest brands, get in touch with our in-house retail experts.

Last week we announced the launch of the new and improved supplier portal, and now our enhanced client portal is also live ….

Along with the all new fresh look, there are new features our clients can now take advantage off, all at no extra cost…

Shortlisted Supplier Questions (SSQ’s)

Clients now have the ability to upload their tender documents to the InTouch portal, invite targeted suppliers to tender and then create additional questions relating to the tender that they would also like to ask.

Only relevant suppliers are invited, and they will only answer the extra questions if they wish to tender. A useful tool to target preferred suppliers, safe in the knowledge that all information in the portal is fully up to date.

Private Notes on Supplier Profiles

We have now given clients the ability to add ‘private’ notes to supplier profiles. These can be personal to user or shared across all users within the organisation if required.

Clients use InTouch as their ‘central supplier pool’ and now they have the added ability to also use it to share notes about these suppliers across their business. This has a huge impact to efficiency and safeguarding.

Search Feature

This upgrade revamps the previous ‘search builder’ tool and is now highlighted as a handy widget on the InTouch dashboard.

Clients have the ability to search, filter, resume searches (previously left unfinished) and save these searches for future reference. Perfect for clients looking to source new suppliers that are Altius Assured.

We are delighted to launch the all new supplier portal, bringing enhanced features, value adds tools and new upgrading options….

Resource Library We have been helping our suppliers to gain their accreditation’s for many years, and now we are sharing our expertise with you

These templates and fact sheets are designed to help suppliers bring improved business efficiency, along with assisting suppliers to gain our accreditation’s.

Templates include: Insurance Method Statement, Risk Assessment, Site Inspection, Subcontractor PQQ, COSHH

Fact sheets include: Requirement, Health and Safety Advisers, PPE, Method Statement, RIDDOR Reporting , SSIP, Welfare Provision, Consultation and Information, Subcontracting, Asbestos, CDM Regulations, Company Overview, CPD, CPD for Health & Safety Advisers, Working with Electricity, Employers Liability Insurance

Introducing the ‘Elite Vendor’ Award Perfect for suppliers wanting to stand out from their competitors by demonstrating a commitment to best practice in the five areas most commonly analysed (Commercial, Quality, Risk Management, Corporate Social Responsibility, and Customer Service)

Elite Vendors receive all the benefits of the Altius Assured award (including CDMComply where applicable) along with:

Priority listing in InTouch and client reporting

Ability to demonstrate corporate and ethical footprint

Personalised Elite Vendor Certificate printed to form part of the welcome pack

Elite Vendor Vehicle and Window Sticker to show your achievement

Elite Vendor Award engraved with their company details to display

Elite Vendors Page Listing to show company logo and profile on www.altiusva.com

Additional Resources to help you improve business efficiency; including Anti Bribery Policy, Environmental Policy Statement, Corporate Social Responsibility Policy Statement, Equal Opportunities Policy, Quality Policy, Environmental Management system fact-sheet.

Additional features due for release over the coming weeks….

Looking to join Altius? Visit our shop for more information, including details on Elite Vendor