Since the first modern slavery statements were published a year ago, we have gained perspective on what companies can do to fight slavery in the supply chain and the benefits of a robust anti-slavery programme. On Tuesday 26th September at 12:00pm, Richard Beale will be joining VinciWorks to discuss the practical aspects of modern slavery compliance and answer any questions you may have.
Meet the expert
Richard Beale is the Global Director of Supply Chain at Marshalls plc. and has over 20 years of experience managing global supply chain and procurement in the FMCG, retail, financial services, private equity and manufacturing sectors. At Marshalls, Richard is piloting a cutting-edge supplier education programme focusing on the elimination of modern slavery.
Ensuring an organization promotes an anti-slavery culture is now more vital than ever. Organisations must therefore ensure their staff feel comfortable bringing up any concerns they have regarding slavery. All staff should be familiar with the organisation’s modern slavery statement and be able to identify a red flag worth raising with their employer. VinciWorks has therefore created a modern slavery whistleblowing policy template that can easily be updated to suit your organisation and staff.
The Modern Slavery Act 2015 has now been in force for over 18 months. The Act means large organisations must pay closer attention to the practices of their suppliers. This includes carrying out audits of their suppliers, investigating the physical conditions of the workforce and being on the look out for instances of child labour. Further, the Act dictates that organisations with a turnover of over £36 million are required to produce a slavery and human trafficking statement.
Huge fines and potentially prison if you breach modern slavery laws
A number of large companies have recently been exposed for having modern slavery in their supply chain. For example, major phone companies Samsung and Apple have faced claims by human rights organisation Amnesty of modern slavery. The claims relate mainly to cobalt mining in the Democratic Republic of the Congo, which is used in devices such as mobile phones and tablets.
30th June 2017 marks the next big deadline for Modern Slavery Act compliance. Organisations with a financial year-end date of 31st December are required to produce a Slavery and Human Trafficking Statement before that date.
Train your staff with our suite of courses
Since VinciWorks released its first course on modern slavery a year ago, thousands of employees and suppliers have used the course as part of their internal compliance programs.
Among the overwhelmingly positive feedback we received, many companies felt they needed a more comprehensive course for procurement teams and a shorter course for general staff. Here is the suite of courses we have created to suit the needs of an entire organisation.
1. Raise your Awareness
General staff in low risk industries
Basic overview and common signs of slavery
In June, the Law Society published its first slavery and human trafficking statement under the requirements of Section 54 of the Modern Slavery Act. This emphasises its call for the legal industry to be at the forefront of the fight against modern slavery. Overall, 87 law firms have published their own modern slavery statements – a good proportion of the medium to large firms that are legally required to.
Of course, while many law firms are publishing their own statements, a key part of a law firm’s work on modern slavery is to advise their clients on fulfilling their legal responsibilities. The Modern Slavery Act doesn’t require much more than the publication of a slavery and human trafficking statement, but how to prepare it, and best practice in doing so, is up to the individual relationship between lawyer and client.
How has the Law Society tackled this problem?
The Law Society set out their statement in three key parts, offering a good guide for those firms still grappling with setting out their priorities for addressing modern slavery in their supply chains.
VinciWorks’ suite of training on modern slavery now includes three courses:
Like all VinciWorks courses, the modern slavery courses can be fully customised to:
- Fit internal procedures
- Adhere to internal style
- Include extra relevant information
In fact, every word of the courses can easily be customised.
Below are examples of the four most common customisation requests that we have collected in order to help organisations better understand best-practice for customisation.
1. Opening quote
The course Modern Slavery: Prevention Exploitation features a quote by Theresa May underscoring the severity of modern slavery. Many firms have replaced this quote with a quote or letter from an executive that reiterates the organisation’s commitment to combating slavery.
This quote sets the tone for the course and conveys the deep responsibility that all staff should feel towards the issue.
The UK’s Modern Slavery Act is changing the landscape of how companies deal with the risk of modern slavery in their supply chains. While the requirement to issue a modern slavery and human trafficking report only applies to companies with a global turnover greater than £36m, businesses of all sizes are getting ahead of the curve and introducing comprehensive anti-slavery and anti-trafficking policies across their supply chain.
VinciWorks has created a suite of training and compliance materials to assist businesses of all types and sizes to comply with their legal obligations and help them to identify and end instances of slavery in their supply chain.
New modern slavery course for procurement teams
VinciWorks has just released a new advanced course on Modern Slavery. A companion to the introductory Modern Slavery: Preventing Exploitation, this 45 minute course is tailored to procurement teams. It gives further insight into modern slavery in supply chains and will help carry out risk assessments. The course can be fully customised to suit internal procedures.
The course includes:
- Common problems to look out for in the supply chain
- High risk countries and products
- Real-life scenarios from different parts of the supply chain to test your ability to spot red flags
- Practical steps for projects
- Questions to ask potential suppliers
- Guidance on addressing risks of modern slavery in your supply chain
Industry-specific red flags
Our course highlights industries where modern slavery is most likely to occur
Click below to demo the course for free.
Demo the course
Around 50% of the FTSE 100’s financial year ends on 31st March
When Should My Organisation Publish its Modern Slavery and Human Trafficking Statement?
The 2015 UK Modern Slavery Act stipulates that all companies with an annual turnover of over £36 million must publish a Slavery and Human Trafficking Statement for 2016. The government guidelines recommend that a company’s Slavery and Human Trafficking Statement should be published prominently on its website within six months of the end of its financial year. Here are the relevant dates for companies to produce their statement:
|Financial Year End||Recommended Start Date||Statement Due Date
|31st March 2016||1st April 2016||September 30th 2016
|31st June 2016||1st July 2016||December 30th 2016
|31st September 2016||1st October 2016||March 30th 2017
|31st December 2016||1st January 2017||June 30th 2017
Here is a practical checklist with the steps you need to take to ensure your statement is published on time.
Our Research shows that around 50% of companies have a financial year end of 31st March. This means that over half of the companies with a turnover of over £36 million should have already published a Slavery and Human Trafficking Statement. As organisations get to grips with the new regulations under the Act, it is clear that not all the organisations are ranking so well.
The findings from a recent report by the Business and Human Rights Resource Centre shows that most organisations are still far from meeting the minimum requirements and showing that they take the Act seriously. The report gives an analysis of the FTSE 100 companies that have a statement due date of 30th September or that have already published a statement. Findings show that:
- Only 56% of the Slavery and Human Trafficking statements met the minimum requirements of the Modern Slavery Act
- In the Structure, Business & Supply Chains category, the average score out of 5 was 1.8
- The Risk Assessment & Management category had an average score of 2.2
- Only M&S provided Key Performance Indicators in their statement, with the Effectiveness category scoring an average of 1 out of 5
- The highest scoring category was that of Due Diligent Processes. Nonetheless, it achieved an average score of only 2.3%
Twelve Months Prior to Publication – Understand Supply Chains and KPIs
- Develop measurable KPIs for your anti-slavery programme
- Review and update your company’s supply chain risk assessment
- Review and update due diligence measures
Section 54 – What Does It Mean For My Business?
The Modern Slavery Act has been in force for little over a year. Some large corporations are already finding it difficult to keep track of modern slavery in their supply chains. For example, in June 2016, farmers Jaqueline Judge and Darrell Houghton were found guilty of trafficking Lithuanian workers to the UK and exploiting them as modern slaves. These men were expected to travel the country to catch chickens and often had lunch breaks and facilities such as toilet breaks withheld from them. This blog sheds some light on section 54 of The Modern Slavery Act.
Section 54, Part 1 – 4: Transparency in Supply Chains
Part 1 – 4 of The Act explains who is required by law to provide a statement and when it must be updated. If your organisation provides a good or service and has an annual turnover of at least £36 million, you are required to create an annual Slavery and Human Trafficking Statement. Here, a slavery and human trafficking statement is defined as a document detailing the steps the organisation has taken to ensure human trafficking and slavery does not take place in its supply chain or business. The statement should be updated each financial year and refer to the previous financial year.