In 2015, the UK government introduced the Modern Slavery Act, giving law enforcement greater tools to identify and apprehend anyone involved in enslavement or human trafficking.
You might not think slavery an issue UK organisations need to be concerned about.
Unfortunately, that’s not true.
The UK saw 16,938 modern slavery referrals in 2022 – a 419% increase on 2015, when the Act was passed. The Home Affairs Committee also estimates at least 100,000 victims of modern slavery and human trafficking in the UK.
Many UK organisations unknowingly work with third parties involved in modern slavery. This most commonly occurs with forced labour in:
Farms
Construction
Manufacturing
However, any industry driven by a demand for cheap products and services is susceptible through its supply chain.
If the UK is to eliminate the threat, organisations must not remain silent. They must take action to identify and report any suspicious behaviour associated with slavery.
In this blog
Addressing modern slavery begins with a modern slavery statement. This blog covers:
What a modern slavery statement is
Who must create a modern slavery statement
Six topics to include in a modern slavery statement
What is a modern slavery statement?
Whenever an organisation is subject to any regulation, it should create a statement outlining:
Its responsibilities; and
The steps it must take to achieve compliance.
You probably have a data protection statement, for example, which outlines the above.
A modern slavery statement is much the same.
The statement must acknowledge the risks of modern slavery and your role in preventing it. You should also outline the policies you’ve introduced to mitigate the threat.
Who requires a modern slavery statement?
According to the UK government, commercial organisations must publish a modern slavery statement if they:
Supply goods or services;
Carry on (part of) of a business in the UK;
Have an annual turnover* of at least £36 million; AND
Are a ‘body corporate’ or partnership, wherever incorporated or formed.
*Turnover encompasses the income of the organisation and subsidiary undertakings, including those operating wholly outside the UK.
What to include in a modern slavery statement
The Modern Slavery Act doesn’t give specific guidance on what a statement should cover or how to structure it.
However, it does include examples of information to potentially include, and how to write the statement.
For example, as a public-facing document, it should:
Provide information you believe of interest to customers and other stakeholders;
Not include confidential information about how your business operates; and
Use simple language to make it easy to understand.
But what about specifics?
Here are six topics to include in every modern slavery statement:
1. Organisational structure and supply chains
Your modern slavery statement should begin with an introduction to your organisation, listing:
Your location, and that of your customers and suppliers (no need to name them!);
Whether you have a parent company or subsidiaries; and
Your products and/or services.
Also state your commitment to social responsibility and the eradication of slavery.
Ideally, reference the Modern Slavery Act by name, and explain that your statement and overall policies comply with the Act’s requirements.
2. Policies in relation to slavery and human trafficking
Next, state that you’ve created policies to tackle slavery and human trafficking.
You can describe those policies in broad terms, but don’t need to go into depth. (Because policies are subject to change – so, if altered, you’d need to rewrite your statement.)
If you do describe your policies, focus on objectives rather than actions. For example, that you’re strengthening your supplier engagement process, or establishing a framework to easily enable people to report slavery.
Alternatively, you can direct readers to another document where they can review your policies. This can be, for example, a page on your website.
3. Due diligence processes
Again, you’re mostly exposed to slavery through your supply chains.
Acknowledge this in your statement, and that you perform due diligence checks on potential partners to identify suspicious activity.
4. Risk assessment and management
As with due diligence checks, recognise the importance of risk assessments and state the steps you take to manage third parties.
While due diligence is more about future or ongoing activities, this section should also detail steps already taken to identify risks. This might include:
On-site audits of organisations in your supply chain;
Employee interviews within the supply chain; and
Annual questionnaires for suppliers to complete.
If you haven’t yet performed any of these activities, use this section of your statement to declare your intention to carry out checks. However, avoid listing specific examples of things you haven’t done yet.
5. Key performance indicators
Use KPIs (key performance indicators) to assess the effectiveness of your anti-slavery measures, such as:
Staff training levels; and
The number of reports on suspicious activity.
Document those KPIs in your statement. However, you don’t need to publish your findings.
6. Training on modern slavery and trafficking
Finally, address the steps you’re taking to educate employees on modern slavery.
This should include a summary of online and in-person training courses you provide to staff. You can also run awareness campaigns, seminars and other appropriate activities.
Some organisations also provide dedicated training and resources page on their website, which employees can view to learn about modern slavery and how to report incidents.
Do your staff know the risks of modern slavery?
If you’re looking to demonstrate your organisation’s commitment to eradicating slavery and human trafficking, our Modern Slavery Staff Awareness Elearning Course can help.
This contains everything you need to identify and eliminate the threat of forced labour. Show staff:
What modern slavery looks like in the UK; and
What role they can play in creating a safe and equitable work environment.
The course also explains the Modern Slavery Act requirements, and how they work alongside ESG (environmental, social and corporate) governance.
Interested in more business essentials topics, like environmental sustainability (ISO 14001), unconscious bias and anti-bribery? Check out our Business Essentials Staff Awareness Elearning Suite for a more cost-effective option.
The post How to Write a Modern Slavery Statement – 6-Step Guide appeared first on IT Governance UK Blog.
