Modern Slavery Audit Checklist

Posted by

Matt Green

on 31 Aug 2021

Modern Slavery Controls to Practise in Your Company

Despite the Modern Slavery Act, huge numbers continue to work in slavery-type conditions in the UK. So how can you help ensure your company is compliant?

Back in 2013, the UK government estimated that ten thousand were subject to modern slavery. But a recent study by the Centre for Social Justice (CSJ) suggests that the figure could be ten times higher.

When the MSA was first introduced, it was considered ground-breaking, with some quietly hoping it would deliver much-needed transformational change.

Almost a decade later, the flagship policy is yet to live up to its early promise. Initial scepticism that this would become just another tick-box exercise now looks prophetic.

Free Modern Slavery E-learning Module

Modern slavery headline figures

  • CSJ believes there could be at least 100,000 victims of modern slavery in the UK based on police data analysis, with the actual number likely to be even greater.
  • 4 out of 10 people weren't sure what modern slavery was, according to a survey by the Co-op
  • 71% of companies believe there is some likelihood of modern slavery in their supply chain, according to the Ashridge Centre at Hult International Business School
  • Less than a fifth (19%) of the UK's agricultural companies currently comply with the MSA - with only 50% publishing a statement (38% of which actually complied with the law)
  • 8% of companies still have no locatable statements, according to TISCreport.org
  • 7 out of 10 FTSE 100 companies (73%) are failing to report sufficient measures to comply with the MSA - scoring below 40% when judged on anti-slavery risk assessments, due diligence, training and policies
  • While the Act allows the government to impose sanctions for non-compliance, it's never been used to date, despite promises to 'name and shame' 17,000 companies that are non-compliant.

Conducting a Modern Slavery audit

Large businesses across the UK must carry out the necessary due diligence in their own company and supply chains to help combat modern slavery and human trafficking.

Under Section 54 of the Modern Slavery Act (MSA), companies with an annual turnover of £36m or more must publish a Modern Slavery Act statement at the end of each financial year, covering their own business and supply chains.

Even though hundreds of investigations are active, the UK Government urges businesses to do more to tackle modern slavery in their supply chains.

Indeed, with an estimated 40 million people now thought to be held in slavery worldwide - more than in the 18th century at the height of the transatlantic slave trade - there's clearly much more to be done.

1. Check your modern slavery statement

When did you last look at your modern slavery statement? Be honest. Perhaps it's time to revisit and refresh that. Assess what improvements you need to make to bring it up-to-date. It's time to go beyond the generic statements and minimum requirements and make it more meaningful.

Modern slavery statements should be:

  1. Published on each company's website with a link to the complete statement placed prominently on the company homepage.
  2. Approved by the board of directors, ideally including the date of approval (according to Home Office best practice).
  3. Signed by a director.

Free Modern Slavery Statement Template

2. Identify modern slavery risks

Only 35% of companies have carried out a risk assessment of their operations, with less than 20% giving information about geographies, commodities, or workers at risk.

It’s important to identify the key risks within your business. Think about which parts of your supply chain or business areas are most vulnerable. Know which products and services are more prone to slavery.

While you will have made efforts to identify these risks when the legislation came into play, how long has it been since you reviewed them? Perhaps now might be the time.

3. Conduct supplier due diligence

Ask your suppliers to provide a copy of their Modern Slavery statement and conduct audits on those that fall into high-risk categories.

Enquire into their operations, how they source labour and materials, the prices paid to their suppliers further down the supply chain, etc.

4. Perform human rights due diligence

Perform human rights due diligence on your business and your global supply chain to better understand potential areas of exposure or key risks in your operations. Engage with local stakeholders in different geographic locations who may have specific awareness of the local operating environment to help identify risks and draw attention to worker exploitation issues.

5. Review workplace modern slavery policies

When the MSA was first introduced, companies reviewed their existing corporate policies regarding slavery and human trafficking and updated them if needed.

However, companies should review these policies regularly to ensure they are kept up-to-date and reflect any changing risks.

  • Are your modern slavery policies as clear as they could be?
  • Are there explicit policies (e.g. covering migrant workers, ethical trading, responsible sourcing or human rights)?
  • Do they align with and reinforce other initiatives (such as UN Global Compact or Ethical Trading Initiative)?
  • Is there anything else you can introduce to take greater control over eliminating modern slavery in your business and supply chains?
  • Is it clear how current policies link to modern slavery, and do they explicitly reference this?
  • Are policies sufficiently detailed, or are they just warm words?
  • Are there policies that deal with non-compliance among suppliers, for example?
  • Is there a willingness to work together to address breaches or alleged exploitation, or will contracts be severed?
  • Are policies, standards and codes cascaded through the supply chain and embedded in contracts?

Any fuzziness may create confusion, at best - or worst-case scenario, result in non-compliance.

Free Modern Slavery Awareness Poster

6. Appoint someone to take the lead

Accountability fosters responsibility. By giving a senior staff member the responsibility for driving forward your efforts to eliminate modern slavery and trafficking in your business and supply chain, it may get a new lease of life.

  • Empower them to drive change forward.
  • Ensure they have the resources they need - e.g. people, time, information, and training.
  • Encourage them to raise awareness and show why this matters.
  • Appoint Champions or mentors across the business who can educate, respond to problems, and tackle worker issues or concerns.

7. Train your staff

Training your staff to spot the signs of modern slavery inside your company and throughout your supply chain is key. Training should focus on red flags to look out for and what to do if foul play is suspected.

Now, you may already have a modern slavery training course. But how engaging is it for your employees? Have you achieved a 100% completion rate? And how relevant is the content to your specific company?

It only takes one person to commit a violation for your company to come under threat. Tailoring off-the-shelf content or creating truly bespoke courses is one way you can make training more relevant and engaging. 

Free Modern Slavery Training Presentation

8. Use modern slavery best practices

Collaborate with peers across your sector and industry to benchmark progress and best practices. Get a better understanding of the modern slavery risks inherent in your business or supply chain to investigate risks and develop initiatives to drive forward industry-wide or sectoral change.

Be open-minded - sign up to initiatives and codes or join working groups (such as Banks Alliance Against Trafficking, Business Against Slavery, Stronger Together) to share intelligence and help combat trafficking.

9. Ethical business: Profit with integrity

Stakeholders and investors need to signal to companies that rigorous due diligence and human rights management demonstrate good governance and effective management. We want more trailblazers and early adopters - companies who lead by example and inspire others to act.

As consumers, we are prepared to vote with our feet and simply won't tolerate abusive practices. Where there's more focus on ethical profit and the 'right culture', business leaders have a greater incentive to monitor their supply chains.

Modern Slavery Training Module

Want to learn more about Modern Slavery?

You can find lots of useful links to key modern slavery facts, figures, tips and training in our comprehensive guide to Modern Slavery Resources.

If you'd like to stay up to date with modern slavery best practices, industry insights and key trends across regulatory compliance, digital learning, EdTech and RegTech news, subscribe to the Skillcast Compliance Bulletin.

To help you navigate the compliance landscape, we have collated searchable glossaries of key terms and definitions across complex topics, including GDPR, Equality, Financial Crime and SMCR. We also regularly report key learnings from recent compliance fines.

You can follow our ongoing YouGov research into compliance issues, attitudes and risk perceptions in the UK workplace through our Compliance Insights blogs.

And if you're looking for a compliance training solution, why not visit our Compliance Essentials Course Library.

Last but not least, we have 70+ free compliance training aids, including assessments, best practice guides, checklists, desk-aids, eBooks, games, handouts, posters, training presentations and even e-learning modules!

If you've any questions or concerns about compliance or e-learning, please get in touch.

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