Guarding Against Slavery in our Supply Chains
Who makes the products we wear every day, have in our homes and eat at every meal?
We think we know and the people who sell them to us think they know too. Yet in some recent cases digging a little deeper has revealed that at the root of cheap prices or big profit margins is a person being exploited.
In November 2015, Nestlé, one of the world’s biggest food producers disclosed forced labour existed in its supply chain. The unusual admission came after a year-long investigation by labour injustice researchers Verité. Their report showed that migrants were sold and lured by false promises to work in Thailand’s seafood sector then kept in debt bondage and degrading conditions.
Uncovering forced labour in supply chains is not just a problem in the developing world.
This month, following a joint investigation between Hope for Justice and West Yorkshire police, a factory owner was sentenced to two years and three months imprisonment for facilitating human trafficking.
The issue is rising up the national agenda and in January 2016 one of the many people rescued by Hope for Justice from forced labour in the last few years was interviewed on BBC Radio 4. He shared his experiences as part of the popular You & Yours consumer affairs show after the UK’s first Anti-Slavery Commissioner took questions on the challenge facing companies of identifying this crime in their supply chains.
New Slavery Statement Requirement for Large Companies
Any commercial organisation with a turnover of £36mn or more must prepare a slavery and human trafficking statement for each financial year under section 54 of the Modern Slavery Act 2015. That’s around 12,000 companies in the UK.
The legal obligation is to either; make a statement of the steps taken in the last year to ensure that slavery and trafficking isn’t taking place in its business or in its supply chains; or make a statement that the organisation has taken no steps.
What might businesses put in their statement?
– Information about the structure of their organisation and its supply chains;
– Policies relating to slavery and human trafficking;
– Due diligence processes in relation to slavery and human trafficking in their business or supply chain;
– Areas within the business or supply chain where there’s a risk of slavery or human trafficking and the steps taken to assess and manage that risk;
– An assessment of their effectiveness in ridding slavery;
– The training available to staff on slavery and human trafficking.
Frontline Perspective: Q & A with Gary Booth, Investigation Team Leader
Why should companies take ownership of this issue?
“First and foremost they have a moral obligation, a social responsibility, to not tolerate slaves in the workplace. Secondly, they’ve got a legal obligation under section 54 of the Modern Day Slavery Act to make a statement outlining what they’re doing to tackle slavery within their business and supply chain – we want to see which companies will establish themselves as the gold standard. Thirdly, it’s good economic and business sense in terms of consumer confidence but also in terms of tender and process transparency.”
Human trafficking seems hard to identify, what should we look out for?
“Many businesses’ supply chains are very complex, they’re very elongated, but there are clear signs that can be spotted within the workplace particularly by those members of staff with responsibility – supervisors and managers. Pay attention to workers who may not be integrated with the rest of the workforce. They may not speak English or, where the rest of the workforce may have their packed lunches and their meals in the canteen, the typical slave has nothing or very little and doesn’t engage with other staff.”
How are Hope for Justice fighting slavery in supply chains?
“Hope for Justice are keen to partner with businesses to support and assist in addressing issues or potential issues. We offer awareness training for employees and suppliers. We’re subject matter experts so we can bring our skills and our services to the workplace and support businesses in a more bespoke manner.
Our work with businesses is about being on the front foot, it’s about actively developing preventative strategies so that a business isn’t having to react to incidents of slavery.
Traffickers exploit numerous people, they exploit the victims but they also exploit unwitting businesses.”
I want to arrange training for my company or raise the issue with a manager, what should I do?
Either you or your manager can contact our UK Head Office on 0845 519 7402 or info@hopeforjustice.org to enquire about general awareness training or a bespoke service.
Why are you so important?
Only time will tell how effective the statement requirement is in creating a proactive approach to seeking out potential victims. We all hope that it will promptly and finally drive would-be gangmasters/labour agents out of commercial supply chains but this will only happen if consumers like you pay attention and make a noise.
Statements must be approved by the Board and signed by a Director then they have to be published on a company’s website with a clear link made visible on their Home Page. If a company fails to produce a statement the Secretary of State can seek a High Court injunction. Companies that fail to comply with the injunction and are in contempt of court are punishable by an unlimited fine. It’s unlikely that a company will just refuse to produce a statement.
Much more likely is that their statement will detail that they’ve taken no steps to tackle trafficking or ineffective steps. If they do that they’ll be in compliance with the law. There is direct punishment for stating that your company is doing nothing or that what you’re doing isn’t up to the job of identifying victims.
Impact is dependent on consumer reaction and media coverage.
It’s left to consumers, investors and NGOs to apply pressure where they feel a company has fallen short of obligations. If we don’t raise the issue in the press and vote with our own pennies and pounds this requirement could potentially become an empty gesture. But if each of us lend our voice to the voiceless and hold companies to account this requirement could create a consumer culture that demands highly educated auditors and rigorously audited supply chains. It could model a major developed economy that’s left no place for forced labour to hide; it could take us one huge leap closer to the end of slavery.
This financial year end is the first time a statement will be due. It will be up to us, the public, to keep a watchful eye on the steps businesses take.
