Transparency in Supply Chains: Improving the Journey

The UK’s Modern Slavery Act 2015 was considered to be world-leading legislation when it was passed. Nearly a decade on, the Home Office has launched new guidance to reinvigorate efforts and accelerate progress in tackling modern slavery. Section 54 of the act now has stronger guidance and examples on how to develop and report on efforts towards more ethical supply chains.

The comprehensive guidance has updated best practices to include consultations with businesses, stakeholders, and relevant charities but also, importantly, takes into account the experiences and inputs of survivors of modern slavery. In combining these sources, organisations are better able to recognise, address, remediate, and prevent occurrences in the organisation and supply chain.

Stakeholders, including investors, will want to have an overview of your business and supply chains for a better understanding of the risks and opportunities of doing business with you. This goes beyond compliance into recognising the value of relationships with your responsible business. 

What’s changed?

The new guidance updates the approach to use not only in the reporting but also in structuring your programmes such as responsible procurement, whistleblowing, recognising signs, and governance and metrics. Here we highlight a few of the key updates in the mindset and approach in bringing your modern slavery programmes towards best practices.

• Risk: it isn’t always about you – One of the important changes in the approach is the focus of the risk. The riskis not only about your business, but now more clearly includes the workers and the impacts on them. This brings to the forefront the ‘S’ in the ESG journey that we’re all on.  
• Cooperation and collaboration: The new approach highlights the benefits of developing relationships and holding discussions with all the relevant stakeholders. This brings the voices of the affected people and also all workers in your business and supply chain into the process. The help of outside organisations, such as NGOs, social enterprises, and charities, adds strength to your programmes.
• Continuous improvement is now to be expected each year. This moves beyond simply ticking the boxes in a written report year on year towards genuinely having deep, meaningful assessments of the potential for modern slavery in your own operations and especially throughout your supply chain and sphere of influence (including investments that you may make). The importance of this is making sure that there is progress each year, in results, metrics, awareness, and actions.

How to develop a modern slavery programme

The steps of developing a strong modern slavery programme including reporting have some adjustments from what you thought might have served up until now: there is more depth and important emphases on the different aspects which were mentioned above.

These steps include:

• Understand your business, and set strong policies and governance.
• Understand your risks and opportunities.
• Map your operations, supply chain, and sphere of influence.
• Identify all key stakeholders and engage with each group as appropriate.
• Address the risks and incidents that you uncover or hear about, including remediation and prevention of future incidents.
• Awareness and education of all agents and employees is foundational; use your leadership position to expand this to your broader sphere.
• Disclose setbacks as well as improvements in your efforts against modern slavery across your industry and society.

These steps may seem daunting, but there is help available in developing your effective programmes on your own ESG improvement journey. Acclaro Advisory has expertise since the UK’s Modern Slavery Act 2015 was introduced, and deep experiences in designing programmes, engaging with stakeholders, and developing Modern Slavery statements across multiple international jurisdictions. Get in touch below if you’d like some support in this area!