Spotting Modern Slavery in Supply Chains

Posted by

Matt Green

on 11 Aug 2022


Many would say their business doesn't tolerate modern slavery. But if you deal with hundreds of suppliers, can you be sure about them too?

Spotting Modern Slavery in Supply Chains

The Global Slavery Index estimates that a staggering 40.3 m people are subjected to some form of modern slavery, 136,000 of whom are in the UK.

Steps to spotting modern slavery in supply chains

Do businesses need to report on modern slavery?

As per the Modern Slavery Act 2015, businesses need to report on steps they have taken to reduce modern slavery in their supply chains.

The UK government has led the way for the public sector to report annually on measures to prevent modern slavery as per the Modern Slavery Act 2015 requirement. The statement published by the government assesses the risk of modern slavery across approximately £50bn of its annual spending.

Public bodies with budgets over £36 million are required to regularly report on the steps they have taken to prevent modern slavery in their supply chains.

The government also introduced a requirement for organisations with budgets over £36 million in all sectors to publish their modern slavery statements on a digital government reporting service.

Free Modern Slavery Statement Template

What are the key questions to ask suppliers?

  1. How have you mapped your supply chain?
    This question reveals whether a company will likely focus on combatting modern slavery. A good indicator is if a supplier has mapped out its supply chain for key products and services.
  2. What does your supply chain look like?
    It is important to get an understanding of where your suppliers' products and services are sourced from and what workers' rights look like within these countries.
  3. What is your response to modern slavery risks?
    This is a key question for obvious reasons. It is important to get insight into whether the supplier has modern slavery and/or human trafficking policies, for example, or if there are consequences for non-compliance and whether employees receive modern slavery training.
  4. How would you describe the working conditions of your workers?
    This question delves into whether the supplier's employees are treated fairly regarding compensation, the right to join a trade union, the safety of the working conditions etc. This insight will give you an understanding of the existing employment relationship and should uncover any suspicious dynamics.
    Top Modern Slavery Questions Answered

What are signs of modern slavery in a supply chain?

1. Physical and psychological abuse

Many victims will look malnourished and may appear withdrawn when you try to communicate with them. Signs of physical abuse could be apparent, such as bruising and other injuries.

2. Restricted movement

Victims may not be allowed to travel alone and will not have possession of their passports. They may seem under the influence of others, have little interaction, and be unfamiliar with the surroundings in which they are working.

3. Poor accommodation

A victim of modern slavery will likely have an extremely poor standard of living, often staying on-site in cramped and dirty conditions with other workers. It is also possible that they would not know their home or work address.

4. Lack of personal belongings

As well as having no form of identification, such as a passport, a victim of modern slavery will likely have very few personal possessions and wear the same clothes every day. These clothes could appear unsuitable for their working conditions.

5. Unusual behaviour

It is quite common for victims of modern slavery to avoid eye contact, continually appear frightened, and allow others to speak for them when addressed directly. They will be very reluctant to ask for help, possibly due to fear of further abuse or deportation.

Free Modern Slavery Awareness Poster

How to tackle modern slavery in your supply chain

Firstly, you must establish visibility by understanding your supply chain and where your products and services come from. Modern slavery can come in many different forms, so it is vital that you can identify the red flags that may indicate a potential problem.

For example, look into recruitment fees, migratory workforces, and be aware of which countries and regions are at greater risk of slavery in the workforce.

Key action points

  • Carry out unannounced spot checks and audits on suppliers - adopt a risk-based approach, so more checks are carried out on suppliers or parts of the business that pose the most risk.
  • Don't impose unreasonable demands on suppliers - excessive production targets or squeezed margins makes it more tempting for suppliers to cut corners or tolerate child labour.
  • Commit to fair and sustainable trade - it's not just about profitability. Remember, we have social and environmental obligations too. It's possible to be both profitable and principled.
  • Appoint local champions - both within supply chains and with external stakeholders and NGOs, who may have expert knowledge of the local climate, identify risks and highlight worker exploitation.
    Free Modern Slavery Training Presentation

Even big brands can be caught asleep

Channel 4's Dispatches visited seven farms linked to Nespresso and five with links to Starbucks in Guatemala and filmed children under 13 working on all of them.

Some worked up to 40 hours a week, carrying heavy sacks full of beans, earning not much more a day than… er, the price of a frothy cappuccino -a clear breach of the regulations set out by the UN's International Labour Organization.

George Clooney, who is on Nespresso's sustainability advisory board and appears in its adverts, said, "I was surprised and saddened to see this story. Clearly, this board and this company still have work to do."

But Channel 4 reporter Antony Barnett said, "It's great that George Clooney supports our investigation, but if he is serious about sorting out this issue, he needs to make sure Nespresso puts its money where its mouth is. It's far too easy to announce an investigation and halt supplies from these regions, but this will further punish the farmers and desperately low-income families who rely on them. These kids are working because their parents – and the farms they work on – are not paid enough."

It is clear that even for those with the best intentions, modern slavery may be happening right under your nose, which is why you need to spot the signs.

Modern Slavery Training Module

Want to learn more about Modern Slavery?

To help you plan and execute compliance in your organisation, we have created a comprehensive modern slavery roadmap.

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