Growing SMEs and the modern slavery statement

Policies – ASOS

You may wish to unveil your policies alongside your values. This could include requirements suppliers are contractually set to meet and programmes that have been put in place to protect all workers.

Take ASOS as an example. It explained: “Our main operational policies related to respecting, protecting and remedying the human rights of all those who work on behalf of ASOS, are our human rights statement and ‘Do the Right Thing – ASOS Code of Integrity’. These apply to all areas of ASOS business and supply chains.

“ASOS has been developing its ethical trade programme since 2008 in order to protect workers against human rights abuses, including forced or compulsory labour. Since 2009, ASOS brand and third party brand suppliers have been contractually required to comply with the ASOS supplier ethical code. This has now been extended to non-stock suppliers.

“In 2016 the supplier ethical code was updated and now includes a separate section providing greater detail on what constitutes forced or compulsory labour, or modern slavery. Related supplier policies that support action on modern slavery include ASOS migrant and contract worker policy and ASOS child labour policy.”

Managing and addressing risk: Due diligence – Tesco

Establishing the framework you’ll use to identify and address modern slavery is key. Tesco is a great example of this, stating: “Risks of modern slavery are dynamic and change quickly. Therefore, we regularly reassess and respond to the potential and actual risks in our business and supply chains.

“To do this effectively, we have put in place a due diligence process, in line with the UN Guiding Principles on Business and Human Rights. The process was developed in consultation with over 50 internal and external stakeholders, including industry bodies, civil society groups, as well as government bodies and agencies.

“The key objectives in developing the due diligence approach were to – as a priority – place respect for workers’ rights at the heart of our strategy and ensure the approach we took would be relative to the risk, allowing us to devote more time to the most important challenges.”

It even included a graphic of the five steps underpinning said process.

Further steps you intend to take – Thames Water

One of the trickiest things about the modern slavery statement is showing actual progress and how you plan to further tackle the issue. This can be anything from workforce training to asking suppliers to meet certain standards.

Thames Water did just that in its “further steps to be taken” section. It emphasised: “Following a review by an independent third party of the effectiveness of the steps we have taken to date to ensure that there is no slavery or human trafficking taking place in our supply chain, we intend to take the following further steps to combat slavery and human trafficking.

“New suppliers will be required to answer additional questions (which we are currently developing), in relation to the approach used to comply with the Act, before any orders are placed by our business.

“These responses will be used to validate the appropriateness of those suppliers being added to our supplier list. Also, further and more tailored training for our ‘Buying Team’ will be rolled out to help them identify and recognise high risk commodities and services when ordering goods or services on behalf of Thames Water.”

Key performance indicators – M&S

That you will be judged on your achievements goes without saying. It’s also worth noting, however, that consumers want to know how you measure your own success. They hope to glean how effective your policy has been.

That’s where M&S comes in. The company explained: “We understand that Modern Slavery risk is not static, and will continue our leading approach to mitigating this risk in the year ahead.

“In order to assess the effectiveness of the measures taken by M&S we will be reviewing certain key performance indicators and reporting on them in future modern slavery statements:

“This includes staff training levels; actions taken to strengthen supply chain auditing and verification; steps taken to upskill our high risk suppliers, and assessing their ability to detect and mitigate modern slavery risk in supply chains; as well as investigations undertaken into reports of modern slavery and remedial actions taken in response.”

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