Is your supply chain hiding a dark secret? 😱
Modern slavery is a hidden crime impacting millions globally, and it could be lurking in your supply chain.
This article outlines 5 actionable steps you can take this week to prevent modern slavery and ensure ethical sourcing.
Read now and take action
It’s late.
You’re lying in bed – doom scrolling through nonsense on your phone.
The unexpected, shrill beep of a text message startles you.
It’s from a work colleague – at this hour?
“You’d better see this”, it says. (May 2024 BBC News link)
The link open up.
Sitting bolt-upright, you read in disbelief.
Your supply chain is in the media – identified as one using child labour.
Another text message arrives.
…and another…
How do you know this won’t happen to you tonight?
You spend your day sitting in a comfortable office, in a comfortable chair, working to ensure the supply of the right products, at the right prices, in the right places, on time, in specification, and in full.
How can you be expected to know whether child labour, forced labour, or slave labour is being used upstream in your supply chain somewhere on the other side of the world?
But, there’s no defending yourself in this situation.
It’s the supply chain you’re paid to manage.
What are you doing to ensure this doesn’t happen to you?
But that’s being selfish and arrogant.
More importantly, what are you doing to ensure it doesn’t happen to them?
Feeling the pressure yet?
“Where do I start?” you ask.
Here are 5 things you can do this week from the desk of your small to medium enterprise (SME) supply chain to prevent modern slavery.
1. Educate Yourself
Child labour, forced labour, or slave labour (modern slavery) isn’t part of my lived experience, or I’m safely guessing, your lived experience.
But today, it is the lived experience of 50 million people and a staggering 41,000 here in Australia.
We need to familiarise ourselves with the signs of modern slavery and how it can be present in our supply chains.
What are the signs of modern slavery?
We all operate an internal radar. We already apply it in our paid role and life, so extending it isn’t a big ask.
Without leaving our desks, here are some easy signals of modern slavery that we can look out for.
Supplier Information can identify a problem:
Supplier Information #1: Pricing and sourcing inconsistencies
- Unusually low prices: If something’s too good to be true, it usually is! If an offer is made for material at a price significantly lower than competitors, it must hit your radar. It could be a sign of unethical labour practices.
- Sudden changes in sourcing: Frequent changes in suppliers, especially in countries with weaker labour laws, are another point on your radar screen.
Supplier Information #2: Red Flags
- Lack of transparency: Difficulty obtaining information about a supplier’s labour practices, factories, or workforce is a cause for concern. Is there something to hide?
- Unwillingness to undergo audits: A supplier hesitant to allow audits or reluctant to answer questions about labour practices might be hiding something.
Supplier Information #3: Contractual Issues
- Unclear or restrictive contracts: Contracts that limit your ability to visit factories or restrict communication with workers could be a red flag.
- Excessive recruitment fees charged to workers: While difficult to uncover from your desk, if a supplier forces workers to pay high recruitment fees, it could be a form of debt bondage.
Supplier Information #4: Workforce Issues
- High worker turnover: Unusually high turnover rates at a supplier’s facility could indicate poor working conditions. Think about what you know already where high staff turnover is driven by a poor culture.
- Unexplained use of migrant or child labour: Again, difficult to uncover from your desk, but is still occurring in industries and countries with a history of exploitation, migrant or child labour.
Time for Lunch
You’ve just returned to the office after a (…messy…) 20-minute lunch break.
You dropped some fish and stained your shirt. Your chocolate thumbprint has now been smeared across your phone’s screen.
In those 20 minutes, you’ve used/consumed the Top 5 Products at risk of Modern Slavery imported into G20 nations by USD value.
They are:
- Laptops, computers and mobile phones
- Clothing
- Fish
- Cocoa
- Sugar cane
Without leaving our desks, where else can we look?
- Responsible News Media : Researching the supplier and the region they operate in for any news reports about labour violations.
- Industry reports: Look for industry-specific reports on high-risk areas or sectors for modern slavery.
Now you have tuned your radar, you have a clearer idea of the signs of modern slavery and how it can be present in our supply chains.
The next natural question is ‘Where are you exposed?’
Modern Slavery: 54% are women and girls
2. Map Your Supply Chain
If you have mapped your supply chain, you understand the origin of your raw materials, components, and finished products. It is easy to use it to identify potential high-risk regions and materials.
If you haven’t mapped your supply chain, check this resource.
What’s next?
Set up a clear policy on how to get on top and stay on top of the issue.
Modern Slavery: 22 million are in Forced Marriage
3. Create a Modern Anti-Slavery policy
There are 50 million reasons to create and implement a modern anti-slavery policy. It’s not just a moral imperative but also a strategic business decision. It can enhance a company’s reputation, ensure compliance, and contribute to its long-term success.
What steps do you need to take?
1. Gather Information and Resources
- Research the anti-slavery legislation and reporting requirements relevant to your company’s location and operations. Follow the lowest common denominator in terms of the requirements.
- Review the modern slavery policies of other companies in your industry.
- At the very least, you can Google “Anti-Modern Slavery templates” and use them as a starting point.
2. Identify Risks and Priorities
- Analyse your supply chain to identify high-risk areas or sectors based on geography, industry practices, or past reports (…remember your 20-minute lunch?). A great place to start is walkfree.org.
- Prioritise your efforts based on this risk assessment, focusing on areas with the highest potential for modern slavery. Google “Modern Slavery Risk Assessment template” to find your starting point.
3. Develop Key Policy Elements
- Company Commitment: Clearly state your company’s commitment to ethical sourcing and eradicating modern slavery from the supply chain.
- Prohibited Practices: Outline the specific practices prohibited, such as forced labour, child labour, and human trafficking.
- Supplier Code of Conduct: Develop a code outlining expectations for suppliers regarding labour practices, working conditions, and adherence to anti-slavery principles. Have them sign up to it.
- Due Diligence Procedures: Establish clear procedures for evaluating potential and existing suppliers, including requesting information on their labour practices and conducting audits when feasible.
4. Reporting Process
Enlist your colleagues in HR and Legal to:
- Create a safe and anonymous way for workers (including those in your supply chain) to report suspected slavery or human trafficking concerns. This could be a whistleblower’s hotline, email address, or designated role.
- Establish clear protocols for investigating reported concerns and taking appropriate action.
5. Collaboration and Communication
- Work with other departments like Procurement, Legal, and HR to ensure alignment with the policy across the company.
- Partner with HR to communicate/train the policy to all staff, suppliers, and stakeholders.
Modern Slavery: 1 in 4 are children
What else can you do?
- Scalability: Tailor the policy to the size and complexity of your company’s supply chain.
- Continuous Improvement: Regularly review and update the policy based on new information and risks.
- Training and Awareness: Develop training programs to educate staff on the policy, red flag identification, and reporting procedures.
Now that you’re familiar with modern slavery, and now that you’ve prepared the company’s Modern Slavery Policy, what comes next?
4. Educate & Train your Supply Chain team to recognise the signs of modern slavery
How can you train your procurement staff to identify red flags of modern slavery?
Awareness Training
Like you, they need to be made aware of the problem. It’s not part of their lived experience. A simple training session can introduce the concept of modern slavery and where it is found in global supply chains.
There is a wealth of online resources from organisations such as International Labour Organization (ILO) or WalkFree focused on anti-slavery efforts.
Red Flag Identification Training
Train your staff to identify the red flags above, such as unusual pricing, a supplier’s lack of transparency, or concerning worker information.
Make up your own examples and scenarios based on your own suppliers and their materials to illustrate how these red flags might appear when they return to their work.
Resources and Tools
Equip your team with resources like checklists or reference websites detailing high-risk countries or sectors for modern slavery.
Provide your new anti-slavery policy and grievance mechanisms for reporting concerns.
Collaboration and Communication
Encourage open communication within the team and across departments (HR, Legal) to share information and concerns.
Establish the process for escalating potential red flags or suspected cases of modern slavery.
Make it part of their standard way of working
Encourage a culture of questioning and critical thinking when evaluating suppliers.
By providing your team with knowledge and tools, you’re empowering them to become active participants in preventing modern slavery within your company’s supply chain.
Modern Slavery: 27.6 million are in forced labour
5. Codify it in your Supplier Code of Conduct
If you already have one, extend it to include modern slavery provisions.
Otherwise, establish a clear Supplier Code of Conduct outlining your company’s commitment to ethical sourcing and prohibiting slavery and human trafficking.
What next?
Do you know what’s happening in your supply chain?
Above are the 5 steps you can take this week to prevent modern slavery.
Don’t wait for the late-night text message.
Act today.
- Download a free Modern Slavery Risk Assessment template.
- Start mapping your supply chain.
- Share this article with your network and encourage them to do the same.
Join the movement to end modern slavery.
50 million reasons are crying out for us to act.
Modern Slavery: We are the key
