Modern Slavery Policy

Policy Statement

  • Prevalence of Modern Slavery: In the United States, the 2023 Global Slavery Index provides a stark statistic, revealing that an estimated 1.1 million people were living in conditions of modern slavery on any given day in 2021. This equates to a prevalence rate of approximately 3.3 individuals per thousand in the population, highlighting the pervasive nature of this issue within the country.

  • Government Response and Legislation: The US government has been proactive in its response to modern slavery, earning a response rating of 67 out of 100. Notable legislative efforts include the Uyghur Forced Labour Prevention Act, enacted in 2021, which aims to combat forced labor practices. Despite these efforts, there remain legislative gaps, particularly in areas such as forced marriage and the establishment of a uniform minimum age for marriage.

  • Vulnerability and State-Imposed Forced Labor: Vulnerability to modern slavery in the US is exacerbated by factors such as discrimination, irregular migration, and organized crime, particularly along the US-Mexico border. A significant concern is the use of state-imposed forced labor within the prison system, a practice that is permitted under the Thirteenth Amendment and excludes prisoners from labor law protections.

  • National Human Trafficking Hotline (NHTH) Reports: The National Human Trafficking Hotline serves as a critical resource in the fight against modern slavery, having received over 10,360 reports of suspected human trafficking cases in 2021 alone. These reports are vital for understanding the scope of the issue and for providing assistance to those affected.

  • International Impact and Demographics: The US, as a major importer, faces the risk of perpetuating modern slavery through its supply chains, with certain goods identified as being produced by forced and child labor. Women and children are particularly vulnerable, accounting for a significant majority of modern slavery victims globally.

This comprehensive overview underscores the multifaceted nature of modern slavery in the US and the importance of ongoing vigilance and action to address this human rights challenge.

Responsibility for the Policy:

The responsibilities for the process in addressing modern slavery within an organization’s policy typically involve several key roles and actions:

  • Board of Directors: The board has the ultimate responsibility for ensuring the policy complies with legal and ethical obligations and that everyone under the organization’s control complies with it.
  • Compliance Team: This team has the primary and day-to-day responsibility for implementing the policy, monitoring its use and effectiveness, and dealing with any queries about it. They also audit internal control systems and procedures to ensure they are effective in countering modern slavery.
  • CEO: The Chief Executive Officer, along with the board of directors, holds ultimate responsibility for the implementation and compliance with the policy.
  • Procurement Team: They are responsible for assessing the suitability and associated risk of suppliers and ensuring that due diligence checks are conducted. They also maintain awareness of preferred supplier relationships across the business.
  • Employees and Workers: All individuals working for or on behalf of the organization, including employees at all levels, agency workers, volunteers, and contractors, are expected to adhere to the policy and report any concerns of modern slavery.
  • Policy Review and Update: Regular review of the policy is necessary to identify areas for improvement and to ensure that it reflects current laws and best practices.
  • Training and Awareness: Providing appropriate training to all personnel on modern slavery and human trafficking is crucial for prevention and compliance.

These responsibilities ensure that modern slavery risks are identified, evaluated, and mitigated effectively within an organization’s operations and supply chains.

Compliance with the Policy:

Compliance with modern slavery policies is essential for organizations to ensure they are not contributing to human rights violations. Here’s a detailed explanation of what compliance typically entails:

  • Understanding the Policy: Employees and all people working for or on behalf of the organization must read, understand, and comply with the modern slavery policy. This includes recognizing various forms of modern slavery such as forced labor, human trafficking, and debt bondage.
  • Prevention and Detection: The responsibility for preventing and detecting modern slavery in any part of the business or supply chains falls on everyone within the organization. This includes avoiding any activities that might lead to a breach of policy.
  • Reporting: If there are suspicions or knowledge of modern slavery practices, it is imperative to report them to the appropriate authorities within the organization, such as line managers or the HR director.
  • Training: Regular training on modern slavery and human trafficking issues is crucial for employees to identify and prevent potential breaches of the policy.
  • Auditing and Monitoring: The policy requires regular auditing of internal control systems and procedures to ensure they are effective in countering modern slavery. The HR and Operations Directors typically have day-to-day responsibility for implementing this policy.
  • Legal Compliance: Organizations must comply with relevant laws and regulations, such as the Modern Slavery Act 2015, which mandates transparency in tackling modern slavery throughout supply chains.
  • Supplier Standards: Businesses are expected to hold their suppliers to the same high standards, including specific prohibitions against modern slavery in contracting processes.
  • Policy Review: The modern slavery policy should be subject to regular review and updates to reflect changes in law, best practices, and the operational environment.

Compliance with modern slavery policy is not just a legal requirement but also a moral imperative to ensure ethical business practices and the protection of human rights.

Communication and awareness of Policy:

Effective communication and awareness strategies are crucial for the successful implementation of a modern slavery policy. Here’s how organizations can enhance awareness and ensure clear communication of their policies.

  • Training and Education: Organizations should provide comprehensive training programs to educate employees about modern slavery, its indicators, and the specifics of the policy. This includes workshops, seminars, and e-learning modules.

  • Awareness Campaigns: Regular awareness campaigns can help to keep the issue at the forefront of people’s minds. These can be conducted through social media, local radio broadcasts, and pop-up events to educate the public on the signs of exploitation and available reporting channels.

  • Internal Communication: Clear internal communication channels should be established to disseminate information about the policy. This can include intranet sites, newsletters, and regular updates during team meetings.

  • Public Engagement: Engaging with the community and stakeholders is vital. This can involve collaborations with law enforcement, NGOs, and other organizations to form action groups that act as intelligence hubs and secure integrated local responses to modern slavery crimes.

  • Reporting Mechanisms: Establishing clear and accessible reporting mechanisms is essential. This includes hotlines, online reporting forms, and designated contacts within the organization for reporting suspicions or incidents of modern slavery.

  • Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

  • Policy Accessibility: The modern slavery policy should be easily accessible to all employees and stakeholders. It should be available on the company’s website and in other relevant places where it can be easily found.

  • Stakeholder Collaboration: Collaborating with external stakeholders, including suppliers, can help to spread awareness and ensure that the policy is communicated across the supply chain.

  • Monitoring and Feedback: Organizations should monitor the effectiveness of their communication strategies and seek feedback to continuously improve their approach.

By implementing these strategies, organizations can create a culture of awareness and vigilance that supports the prevention of modern slavery and ensures compliance with the policy.

Breaches of this Policy:

Breaches of modern slavery policies are taken very seriously due to the severe impact they can have on individuals’ lives. Here’s how breaches are typically handled within organizations:

  • Employee Disciplinary Action: Any employee found to have breached the policy may face disciplinary action, which could result in dismissal for gross misconduct.
  • Termination of Business Relationships: The organization may terminate its relationship with suppliers, contractors, and other business partners if they breach the policy or are found to have been involved in modern slavery.
  • Reporting Mechanisms: Employees are required to report any activity that might lead to a breach of the policy. Failure to do so can also be considered a breach of the policy itself.
  • Legal Consequences: Depending on the severity of the breach, there may be legal consequences, including fines and penalties for the organization and individuals involved.
  • Reputational Damage: Breaches can lead to significant reputational damage, affecting the organization’s public image and potentially leading to a loss of business.
  • Review and Remediation: After a breach, the organization will typically review and remediate the affected areas to prevent future occurrences.

It’s important for organizations to have clear policies and procedures in place to prevent, detect, and manage any breaches effectively.

Document Review

The policy is subject to an annual review.

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