Companies must carry out a modern slavery business risk assessment on all their major supply chains and internal processes. The purpose of assessment is to identify the vulnerable components of their supply chains and internal processes that can be most at risk from modern slavery due to geography or sector-based risks or due to other factors that contribute to the exposure of vulnerable workers (e.g., work for just a few hours or a few days, low wages, long working hours, limited job opportunities). This assessment must include assessing all the key relationships in the supply chain and processes that relate to the supply chain. This assessment should understand all labor, management, and market structures present in the supply chain and what these relationships mean for the workers who perform the various tasks in the supply chain. Furthermore, a practical assessment should also provide information about the status and health of all the workers subjected to these conditions.
For a successful modern slavery risk assessment, companies should first develop and maintain adequate policies for their suppliers. Such policies should ensure that all workers, including both temporary and permanent employees, are paid and that they have access to a workplace and to all other services and facilities provided by the company that employs them. The policies should also include provisions for monitoring all employees, including the frequency of checks conducted, the outcome of assessments, and whether any company policy infractions were found. In addition, adequate and efficient procedures must be in place for checking and controlling the hiring, training, and employment of all new staff members and their subsequent performance and treatment when released from employment. Such procedures should also include provisions for performing random and periodic re-verification of the background of all potential employees to ensure compliance with all the policies and procedures of the company.
Another aspect of modern slavery business risk that must be addressed through the application of supply chain risk controls is the recruitment of employees through forced child labor and slave trade. The modern-day slave trade is a sadomasochist symbol of contemporary corporate capitalism’s disregard for the lives of children and the dignity of workers. The best practices of corporate social responsibility should prohibit the hiring of slave workers and investigate all reports of incidences of forced child labor or slave labor participation. Furthermore, these measures should be extended to all areas of the supply chain. Prevention and response measures should include policies concerning recruiting individuals who have received training in abusive work practices or criminal conduct and those who are or have been associated with terrorist groups recruiting slave laborers.
