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Our European Programme and Advocacy Co-ordinator, Klara Skrivankova, on what businesses must do to tackle slavery in their supply chain.
31 March 2016
From 1 April, the first group of companies will have to start disclosing the steps they are taking to tackle slavery in their supply chains under the Transparency in Supply Chains Provision (TISC) of the UK Modern Slavery Act 2015.
Requirements on disclosure and transparency on modern slavery mark in many ways a new era. Full transparency will be expected by civil society and consumers who are increasingly becoming aware that there is no such thing as a “slavery-free” supply chain. It is important that companies who inform the public that they have uncovered a modern slavery concern and who are taking steps to address it should be hailed as leaders.
In the months following the entry into force of the provision last October, there has been much debate about who should be reporting and what they should include in their statements. A number of businesses have reported early, but most of the reports published to date lack detail and demonstrate their limited understanding of the problem. Some are more of a PR exercise than a reflection that the issue is taken seriously.
Anti-Slavery International and many others would like to see a race to the top in company disclosure, with businesses not only making sure they understand the problem, but committing at the highest level to change their business practices.
A civil society guidance, to which we also contributed, gives businesses an idea of what NGOs expect. The ultimate benchmark of “what good looks like” will not be the procedural changes that a company introduces, but how those changes reduce the risk of slavery in its supply chains and improve the situation of the most vulnerable workers.
What can businesses do to get ready to tackle modern slavery in supply chains?
Information and knowledge are key. This includes understanding modern slavery and knowing how to address it using credible sources of information.
To start with, companies must be aware where in their supply chains the greatest risks of modern slavery lie – is it a country, particular industries, the form of employment?
This last issue in particular is one of the key causes of concern in the UK. Many so-called ethical auditors overlook problems in the UK and Europe because these locations are considered “low risk”. Our research, numerous media reports and recent legal cases suggest otherwise. Temporary, migrant and agency workers in labour supply chains in the UK are often in precarious situations and are very vulnerable to exploitation by unscrupulous agents.
Sub-contracted labour is used extensively in many industries in the UK. Take hospitality. While not often in the public eye when it comes to modern slavery concerns, cases of labour exploitation in UK hotels are well known.
Knowing your workforce, even if they are not directly employed, and making sure that they are aware of their rights, is a key step every responsible hotel should take to prevent risk of slavery in their supply chain.
There are some basic steps everyone can take. For example, our Staff Wanted Initiative, a joint project of Anti-Slavery International and the Institute for Business and Human Rights, developed a set of tools for UK hotels to identify the risks and to provide information to workers. A brand new poster with basic information for workers in ten main languages is being circulated to all hotels within the Greater London area and is downloadable from the website. By putting the poster up, a hotel manager can take the first step to reducing the vulnerability of agency and temporary workers.
Over the past months, there has been a proliferation of consultancies offering businesses quick and simple solutions. It is important to note that unfortunately there is no quick and easy solution to a complex problem like modern slavery and many of those offering quick fixes lack credibility and have minimal knowledge of the issue.
Sub-contracting responsibilities in one’s supply chain is a great risk, as evidenced by the widespread failures of audits to uncover forced labour. The tendency of businesses to outsource (which led to complex and often impenetrable supply chains in the first place) is a great risk in itself when it comes to building knowledge and capabilities to tackle modern slavery.
While it is important for businesses to obtain understanding of modern slavery with the help of others at first, eventually the basic knowledge and skills need to be embedded within a business if addressing the risks of slavery in the long term is to be taken seriously.
Follow Klara on Twitter: @klaraskriv
