Beyond compliance: Effective reporting under the Modern Slavery Act
This report provides practical guidance from non-governmental organisations with expertise in modern slavery for commercial organisations reporting under the UK Modern Slavery Act. It provides a business case for business action on modern slavery in supply chains that goes beyond minimum compliance to achieving positive change on slavery and forced labour.
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OVERVIEW
This guide prepared by CORE Coalition and related civil society groups is intended to compliment the UK Government Guidance and provides ideas for how companies can respond effectively and link actions to address slavery to broader thinking about human rights due diligence.
The authors set out reasons why businesses should be concerned about modern slavery and describe some of the benefits of aiming beyond minimum compliance. They provide a series of summary recommendations for how this may be done followed by more specific advice on understanding and addressing risks. The report concludes with specific advice on drafting a strong modern slavery statement.
The authors observe that companies that have an honest and transparent view of their supply chains and back that up with strong action and communication have better results when compared to a compliance only approach. Effective actions can enhance corporate reputation and image, and taking an active role will bring benefits to companies. These benefits include improved risk assessment and management, investor relations, consumer relations, employee engagement, recruitment, retention and motivation and more sustainable business relationships.
Outlined in this guide are ideas for how companies can respond effectively and link actions to address slavery to broader thinking about human rights due diligence. These actions are largely centred around risk assessment and can be summarised as follows:
- Take action to understand the risks of modern slavery occurring in business operations, paying particular attention to business models, operating context and the nature and location of work;
- Develop comprehensive policies which will influence decision-making within the business on a day-to-day basis in relation to slavery and human trafficking including mapping these risks;
- Consult internally and externally with key stakeholders, including people who are, or could be affected by modern slavery, and those organisations representing them.
- Develop clear action plans to prevent and mitigate modern slavery;
- Develop a process for informing business decisions – including the selection of suppliers, subcontractors, or third-party recruitment agencies – based on performance on policies and practices regarding labour rights issues;
- Include clauses on modern slavery and risk factors in contracts with suppliers, and closely monitor suppliers;
- Put in place procedures for reporting concerns over modern slavery within the company’s operations and communicate these effectively;
- Publish the Statement as soon as reasonably practicable after the end of the financial year; and
- Make the Statement easy to find online and undertake promotional activity.
Investors looking to measure corporate effectiveness on modern slavery may use this guidance to inform their assessments of the quality of companies’ disclosure and action to meaningfully reduce slavery in supply chains.
KEY INSIGHTS
- Modern slavery reporting is an emerging and growing form of legislative corporate accountability.
- A company’s modern slavery statement should provide information on the steps the company has taken to identify, minimize and respond to the risks of slavery occurring in their supply chains.
- All companies should aim to work jointly with civil society and other stakeholders, including employees, suppliers and investors, to address risks.
- The key benefits for investors is that reporting is a key indicator of compliance with a companies legal requirements under the Modern Slavery Act and it also provides an additional source of information when it comes to ethical investing and ESG considerations.
- Detailed modern slavery reporting is another measure of good risk management and governance.
- Companies that provide better reporting and set measurable actions for improvement are more likely to attract investment.
- Consumers are increasingly expecting more ethically aligned products and services, and more rigorous modern slavery reporting naturally fits with more sustainable business models.
- Risks of slavery are higher in certain business models, operating contexts and geographic locations. Business should be aware of these and provide detailed examples of how they are addressing these risks.
- Specific information about what investors can do to help address modern slavery is available from ShareAction.
RELATED QUOTES
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“It is not acceptable for any organisation to say, in the twenty-first century, that they did not know. It is not acceptable for organisations to ignore the issue because it is difficult or complex. And, it is certainly not acceptable for an organisation to put profit above the welfare and well-being of its employees and those working on its behalf.”
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