Modern Slavery Policies – is yours just a piece of paper?

Companies cannot be wholly blamed for putting little investment into practices that deliver commitments to mitigate the risk of modern slavery, the current UK legislation enables this behaviour, which is now lagging behind other legislations across the globe. The Financial Reporting Councils’ last report on Modern Slavery Reporting practices highlighted 12% of companies not having a statement and only 14% of companies linked their annual reports to their modern slavery statement. The FRC summarised the statements reviewed as largely superficial and description, lacking in critique or measurement.

Nutral’s findings highlight whilst 100% of companies have Modern Slavery policies or statements 72% stated not having practices in place to deliver the commitments made in those statements. This correlates with the FRC’s findings further supporting the case for increasing the UK’s current legislation as it is effective in addressing the issues.

So, what can your team do to better assess a Modern Slavery policy? Key things to look out for:

Has the policy evolved from the previous year or has the expiry date just been changed?

Is there a narrative on how they came to form the policy? A working group for example.

Are there any measures in place and if so, are they providing statistics from those measures? For example, if you are going to run training then how many people did you train?

Is the company seeking specialist advice or guidance? If so, who from? How have they supported your strategy?

The construction sector’s current pre-qualification processes are heavily based on policy checks rather than a company’s actions to deliver against their policy. This will put more pressure on procurement and supply chain teams to better understand their supply chain practices so they mitigate risk as well as support their development.

On a weekly basis, I am asked what the biggest challenges are for addressing modern slavery and I still believe that currently, it comes down to organisations taking it seriously. Modern Slavery needs to be addressed as part of a wider social sustainability initiative to help get the investment in practices needed. Social Sustainability covers people and communities. If a company is taking these elements seriously then it will naturally make it harder for modern slavery to be present. For example, if you are working with your supply chain to ensure they pay agreed wage rates, provide employment benefits, drive EDI, support local communities, have practices for management bullying or harassment, Worker fatigue management practices, health, and well-being initiatives…then all these activities are reducing the likelihood of Modern Slavery being present. Not only that, but they are also making a company better to work for which helps drive productivity, attract talent, and reduce churn…making the company ultimately more successful and thus more sustainable.

Whilst the UK’s legislation is lacking other nations are progressing. The new EU Taxonomy for Sustainable Investment is another driver for companies to take more action to address Human Rights. Legislation aside, Social Sustainability is a growing topic for construction and has become a necessity for commercial growth. So, when your business asks what are we doing to mitigate Modern Slavery step back and ask what are we doing to improve the working lives of the people in our value chain.