Modern slavery in supply chains is an ongoing concern for many businesses, but key industries and jurisdictions present a much higher risk of modern slavery than others.
A recent UK government review of modern slavery and human trafficking in the supply chain for the NHS has revealed that 21% of NHS suppliers are at high risk for modern slavery in their supply chain. Additionally, the top imported products at risk for modern slavery are critical PPE items, including surgical instruments, gloves, gowns, uniforms and face masks.
Although all business in the UK with £36m in turnover or more are required to undertake an annual modern slavery risk assessment and publish their findings, the Health and Care Act 2022 requires all parts of the NHS supply chain to embed modern slavery due diligence in the procurement process.
With increasingly globalised and complex supply chains, a lack of transparency increases the difficulty for organisations to know about conditions for workers in their supply chain. Of the suppliers identified as medium and high risk in the recent review, the majority of tier one suppliers were registered in Great Britain (51%) and China (28%), with a substantial reduction for other countries thereafter (Pakistan 3%).
While many NHS tier one suppliers are registered as based in the UK, they have global supply chains that consist of multiple layers of suppliers that can be based in multiple and different locations throughout the world.
Where are the modern slavery risks?
China remains at significant risk for modern slavery and human trafficking given the ongoing human rights abuses being carried out by the Chinese Government in the western Xinjiang province, home to the Muslim Uyghur population. Hundreds of thousands of these people have been forced into labour camps by the Chinese authorities in ongoing crackdowns on human rights. The US and other countries have been taking legislative and executive action to place barriers on goods coming in from the Xinjiang region which are at high risk of modern slavery.
Raw materials for the production of key products in the NHS supply chain are also under scrutiny. Cotton is one such high risk item which remains high risk throughout the life cycle, from cotton-pickers to textile factories.
The Xinjiang region of China is also a centre of cotton and textile production, alongside Turkmenistan, another repressive state. In these places, people are forced into work and subject to limited freedom of movement and communication, constant surveillance, retribution for their ethnicity and religion, along with various threats to family members and often abuse and coercion. The US has banned all cotton imports from Turkmenistan because of the abuses in the country.
It’s thought that at least 10% of items in the NHS catalogue have cotton in them in one form of another.
The PPE supply chain and modern slavery
The risk of modern slavery in PPE supply chain was highlighted by the example of the Malaysian glove supplier that was reliant on migrant workers, and reported exploitative practices including debt bondage, restriction of movement and association, with allegations of similar violations of forced labour in China, including for face masks.
In addition to forced labour of Uyghur populations, allegations have been brought of forced labour of hundreds of North Korean workers in China, producing PPE.
Fortunately, there are many ways that businesses can reduce the risk of modern slavery and forced labour in the supply chain. Innovations and changes such as requirements in contracts, expecting suppliers to sign up to global and industry standards, alongside risk assessing suppliers and jurisdictions, can make a significant impact on reducing the risk, and to comply with legislation.
VinciWorks modern slavery resources
Free Modern Slavery Statement Template
VinciWorks has created a free Modern Slavery Statement template that can easily be customised to suit your organisation.
Whistleblowing template
What should the modern slavery whistleblowing template include?
Your company’s whistleblowing policy should make the procedure for reporting slavery and human trafficking concerns clear and easy, as well as ensuring staff feel comfortable and safe to make a report. Here is a guideline of what should be included in the policy.
- Introduction to the Modern Slavery Act
- When to use the whistleblowing policy
- Procedure for responding to concerns raised
- The importance of confidentiality
- Protecting the whistleblower
Modern slavery course collection
VinciWorks’ modern slavery training suite offers a variety of training options for companies to use as part of their internal compliance programs. Our courses are designed to meet the needs of an entire organisation, from general staff to procurement teams.
Raise your Awareness
Target audience – General staff in low risk industries
Duration – 10 minutes
Course outcomes – Basic overview and common signs of slavery
Preventing Exploitation
Target audience – General staff in high risk industries
Duration – 20 minutes
Course outcomes – Comprehensive overview of the issue with red flags and common signs of slavery
Practical Steps for Procurement
Target audience – Procurement, HR and management
Duration – 40 minutes
Course outcomes – In-depth training on red flags when dealing with suppliers
Modern Slavery Knowledge Check
Target audience – All staff
Duration – 5 minutes
Course outcomes – A 10 question overview of modern slavery to test knowledge