Action Guide
Practical steps for every project
Practical steps for making procurement decisions
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To do list for new projects
  • Review country risks by checking the human rights record, status of labour laws and freedom of trade unions and civil society.
  • Map supply chains to their furthest point and prioritise what requires further investigation by volume and value.
  • Identify direct and indirect causes and impacts of trafficking and slavery by understanding employment relationships with suppliers and analyse vulnerability of workers (e.g. migrant or child workers).
  • Identify risks to workers by sector, type, employment status and market dynamics with particular attention to high risk sectors, countries and employment relationships.
  • Review HR systems and recruitment practices including use of agents, subcontractors, recruitment practices, third party agents, fees, retention of worker IDs and potential of debt bondage.
  • Assess workers’ ability to access rights of freedom of association and collective bargaining, particularly rights of migrant workers in unfree states.
  • Rank risks by severity, scale, and responsibility to assess the causes and contributions, impact, leverage and influence.
  • Analyse the data and create an action plan through collaboration with stakeholders, prioritising areas of greatest risk and leverage and undertaking specific actions.
To do list for existing projects
  • Assess the scale and scope of corporate responsibility, how far the company has contributed or caused the risk, and specific actions to mitigate and manage these.
  • Assess leverage with suppliers, agents and contractors including degree of trust, stability of supply and nature of business partnerships and engage in capacity building of suppliers to take action rather than top-down compliance.
  • Review sourcing strategies and purchasing practices that focus on countries at risk and whether prices paid to suppliers enable living wages and safe working conditions.
  • Review supplier capacity to manage labour risks on areas such as recruitment, pay, working hours, health and safety, and anti-discrimination.
  • Establish benchmarks and procedures for monitoring improvements or terminating contracts with suppliers if conditions fail to improve.
  • Ensure policies and procedures enable workers to exercise their rights to collective bargaining and communicate policies with suppliers across the supply chain.
  • Review corporate decision making, accountability and risk management policies and promote senior management level commitments.
  • Identify opportunities for collaborative action through experts in the sector, NGOs, local government, and other companies in the same industry.
Found evidence of slavery? Start here
  • Take immediate steps against human rights abuses by engaging with workers impacted, apologising for harm caused and agreeing immediate actions to prevent further harm.
  • Provide remediation for workers through financial or other compensation to victims, reinstating workers who have been unfairly dismissed as a result, and ensure victims are not further persecuted or harmed.
  • Identify changes to working practices and act on them whether it is recruitment, purchasing, pay, agencies, or other areas.
  • Establish or revise grievance and remediation systems that are trusted by workers, have clear lines of responsibility and communicate policies and procedures to all workers and suppliers in the chain.
  • Enable workers to access their rights to freedom of association and collective bargaining by providing democratic representation where no trade union exists and secure direct contracts to allow workers to negotiate with the employer rather than via an agency.
  • Undertake a social audit of workplaces to identify opportunities to further mitigate risks and remedy potential problems.
  • Implement strict code of conduct agreements with all suppliers and contractors that takes mitigated risks and remedies into account and sets them as conditions of the contract.
  • Consider and plan for changes across the business planning spectrum to rectify procedures that caused the risks.
Reviewing existing policies? Start here
  • Track mitigation and remediation actions by establishing what is occurring, whether it is effective and independent verification of changes and their impact.
  • Review decision making responsibility and accountability through assessing company decision making systems, board level responsibility, KPI’s at corporate level and agreeing on consequences for failure to act.
  • Review information sources to ensure evidence is credible, verifiable, relevant and robust, and consider independent third party sources.
  • Analyse evidence, learn lessons, and prioritise actions for long term prevention through documenting all parts of the process.
  • Communicate internally and with business partners on human rights work with consistent and clear staff training and policies to mitigate labour exploitation.
  • Publicly report on progress through the modern slavery and human trafficking statement.
  • Build partnerships and collaborative action with partners in civil society, business, trade unions, and other stakeholders.
  • Implement comprehensive, effective, and mandatory training for staff at all levels of the business and cascade it throughout the supply chain.
New projects
Found evidence of slavery?
Reviewing existing policies?