Despite the enactment of modern slavery legislation around the world, staggering numbers of people still work in unlawful and slavery-like conditions. To address this, organisations everywhere are in a position of responsibility to conduct thorough human rights due diligence of their supply chains to protect the interests of vulnerable people and their organisation’s reputation.
This will not only help them to prepare a modern slavery statement and report, but a thorough due diligence programme will enable them to hold themselves and their supply chains accountable for providing adequate working conditions for all of their employees.
We explore the ins and outs of a modern slavery assessment, where to start, and how to effectively identify modern slavery risks throughout your supply chain.
What is a modern slavery assessment?
Businesses across the globe are responsible for conducting due diligence to ensure their supply chains are not engaged in modern slavery or human rights violations. By not conducting adequate due diligence pertaining to modern slavery, organisations risk failing to meet reporting obligations. There are also ethical implications that affect reputation, as well as customer and supplier retention.
The best place to start is by conducting a modern slavery risk assessment. This assessment of your organisation’s operations and supply chain includes following certain steps to sweep all areas of your organisation, and every third-party affiliation and supplier to identify risks of modern slavery. Although a complete assessment will look different for every company, there are some essential places to start and common steps to include for every business.
Preparing to conduct a modern slavery risk assessment
The first step is to map your organisation’s structure, businesses, and supply chains and formulate policies and procedures in relation to modern slavery. The next step is to identify those parts of the business operations and supply chains where there is a risk of modern slavery and conduct a risk assessment of your supply chain.
The Modern Slavery Supplier Risk Assessment Questionnaire brings together Norton Rose Fulbright’s global human rights expertise with the ethiXbase 360 powerful Third-party Risk Management platform to help your business identify and manage modern slavery risks throughout its supply chains. The questionnaire is designed to help narrow down the steps your organisation needs to take throughout its risk assessment based on the unique conditions of your business.
The Modern Slavery Questionnaire applies a weighted equation that includes jurisdictional, industry, and contractual risk factors to identify areas of concern across your entire supplier database. The questionnaire uses five key indicators to assess a supplier’s level of risk:
- Jurisdiction: the country of operations and headquarters
- Industry: the industry of supplier, as well as goods or services produced and supplied
- Products: products attributed to high risk of modern slavery
- Workforce: characteristics of the staff employed by the supplier
- Risk-mitigating measures: efforts in place to remediate risks specific to the individual supplier
Depending on how your suppliers score in each of these categories, you can act to manage the risks identified.
Conduct a modern slavery assessment
As mentioned earlier, a modern slavery assessment will look different for every company, as organisational modern slavery assessment.
Develop a modern slavery or human rights policy or commitment
If your organisation does not already have a modern slavery or human rights commitment, it’s time to develop one. This document presents to the public your business’ intent to uphold human rights. If your company already has a commitment, consider how it is being implemented.
Involve cross-functional teams
Modern slavery compliance risks can develop in any facet of your organisation. Involve team members from every department to ensure that potential risks are identified in any area.
Develop location-based regulations
Modern slavery or human regulations vary between jurisdictions. Stay on top of what modern slavery reporting looks like in your country, as well as the countries within which your organisation and supply chains operate.
Perform ongoing assessment
Modern slavery reporting is not a set-it-and-forget-it process; requirements change frequently and it can be very easy for new risks to develop. Perform due diligence regularly, not only when a problem arises or when preparing your modern slavery report.
Work with ethiXbase
Even with all the tools to perform an adequate modern slavery assessment, it can still be challenging for organisations to know where to start, and even more challenging to mitigate risks in a timely manner and not fail compliance evaluations.
Consulting with ethiXbase can:
- Effectively map supply chain and identify potential modern slavery risk
- Provide seamless third-party onboarding to create a singular view of the supply chain
- Offer an analytics dashboard with a real-time picture of your supply chain
- Leverage automated workflows to save up to 80% of admin time in the administration and management supplier responses
- Enable board reporting in relation to supply chain risks and the impact of strategies to manage that risk
- Perform ongoing risk monitoring
Modern slavery regulations are perpetually changing around the world, and the fight against modern slavery conditions continues throughout third-party supply chains. It’s the responsibility of organisations to manage their modern slavery risk, but knowing where to start with a modern slavery assessment can be daunting.