Modern slavery in local government supply chains: transparency statement guidance and procedures

Front cover Modern slavery in local government supply chains
To accompany existing guidance on Modern Slavery transparency statements, this guide is aimed to give you practical advice on how to draft your first statement; what to include; where to publish it and how to avoid some of the common pitfalls as well as offer some practical procedural suggestions when carrying out supply chain due diligence.

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Introduction

To accompany existing guidance on Modern Slavery transparency statements, this guide is aimed to give you practical advice on how to draft your first statement; what to include; where to publish it and how to avoid some of the common pitfalls as well as offer some practical procedural suggestions when carrying out supply chain due diligence.

It can also be used to assist those looking to build on previous statements; to implement year-on-year improvements and evidence the practical progress on how you are tackling the risks and incidence of Modern Slavery in your operations and supply chains.

Mandatory requirements

Publication and accessibility
DO DON'T
Report annually on the past financial year within six months of your organisation’s financial year-end Report either in advance of the end of a financial year or after six months of your organisation’s financial year 
Improve the statement year on year - it is a live document   Reproduce your old statement with minor word changes or merely altered dates 
Keep a record of old statements accessible to the public (providing URL links etc). This allows for progress to be monitored  Delete old statements, only have the current statement publicly available  
Publish the statement in a prominent place on your website, eg bottom of homepage or obvious drop-down menu  Publish it in a place difficult to find or password protected  

 

Formulation and approval process
DO DON'T
Ensure the statement is approved at the highest level and signed by a senior member of the organisation (chief executive/leader of the council); providing their post and name, signature and approval date Leave the statement unsigned/dated or in draft format; simply state it has been approved without specifying
Ensure the statement is a genuine reflection of your business, practices, and culture  Use templates without making the statement your own 
Formulate the statement as a collaboration between departments, with procurement teams leading and others participating eg human resources, legal and safeguarding teams  Leave it to one department or person to write the statement without input and contribution of others
Provide relevant information in your statement with sufficient detail  Use the statement to showcase non-Modern Slavery and human rights related activities and overwhelm the reader with excessive details, i.e. too much legal or technical information 

 

Substantive content of statements

Organisational policies
DO DON'T
Showcase your Modern Slavery policy if you have it and explain the link between your existing policies and Modern Slavery   List or reproduce all of your organisational policies  
Amend existing policies to include references to Modern Slavery or create a standalone Modern Slavery policy Refer to policies that have no relation to Modern Slavery  
If approving a standalone Modern Slavery policy, clearly set out the obligations on staff, suppliers, business partners and agents, as well as procedures to be followed   Create a Modern Slavery policy composed of a collection of empty statements with no clear impact on your council’s work and behaviour eg. merely referring to a zero-tolerance approach is not enough 
Clearly state who is responsible for the implementation of the relevant policies, how implementation will be monitored and how it should be reported on   Publish a policy without a responsible department/person and an enforcement, reporting and review mechanism
Circulate policies in your organisation and relevant parties to make it known to all and explain how this is done in the statement   Have policies your staff, constituents and customers, business partners, suppliers and other stakeholders don’t know about and wouldn’t be able to find unaided

 

Due diligence: identifying and prioritising risks

DO DON'T
Show you understand the risks of abuse your organisation and practices pose:
  • towards your own staff 
  • related to recruitment practices (including use of agencies) 
  • related to sub-contracting
  • related to the products/services you procure
  • in your supply chains  
Reproduce the risks found in other statements or templates without assessing how they relate to your own practice and suppliers 
Consider risks associated by country; sector; transaction; and business partnerships as set out in Tackling Modern Slavery in Government Supply Chains Guide for Commercial & Procurement Professionals State that procuring solely from the UK means your supply chains are at a low or no risk of Modern Slavery. Modern Slavery is occurring every day in public sector supply chains in the UK
Highlight your high-risk areas, whether product or service based, in your supply chain  Merely list all products or services procured
Prioritise risks and focus on high-risk supply chain mapping Try to map all of the supply chain at once
Understand that risks may change   Reproduce the same risks year on year in your statement

 

Due diligence: preventing, mitigating and remedying abuses

DO DON'T
Ensure that you have functioning and responsible procurement and contract management due diligence procedures to minimise risks of modern slavery taking place within domestic and global supply chains. For example: 
  • referrals, site visits and spot checks 
  • contractual provisions and contract monitoring and management
  • asking for suppliers to provide their own due diligence of their sub-contractors and supply chains
  • use online modern slavery risk identification and management tool such as the government’s Modern Slavery Assessment Tool (MSAT)

Do not make ambiguous and generalised declarations stating that you take all appropriate measures without providing details 

Seek assurances from suppliers during the tendering process. Ask the questions up front and probe responses, where appropriate
Pre-procurement specification, questionnaires and checklists can be found in Tackling Modern Slavery in Government Supply Chains

Solely rely on a checklist and allow this to become a tick box exercise 

Introduce Modern Slavery related clauses into contracts and terms and conditions and use them to engage with suppliers meaningfully, making your expectations clear

Simply inform suppliers of your policies or ask them for theirs and seek vague anti-slavery assurances  

Work with suppliers to create action plans, take corrective measures, and if suppliers refuse to cooperate, consider measures against them 

Immediately terminate the business relationship 

When contracting services robustly question recruitment processes  

Use minimal vetting techniques, or state that you use ‘reputable recruitment agencies’ which you have not assessed 

Report on planned monitoring and auditing measures for your own sites and sites of your suppliers

Outsource the responsibility to your suppliers, merely assuming they will carry out adequate monitoring

When using third party audits engage in the process and create action plans  

Rely on the audit without a follow-up

Identify and report violations, and address how you will mitigate them

Hide or dismiss violations or rely on suppliers to resolve them when they take place lower down in your supply chain

Establish Modern Slavery working groups internally in which relevant departments are involved to address instances where you have identified risks or actual abuse

Make due diligence the responsibility of one sole individual or department in the institution – it is an organisation wide process

Review these procedures annually and continuously seek to innovate and improve on these over time

Be complacent that current due diligence practices will always mitigate the risk of Modern Slavery in your supply chains - unscrupulous suppliers will always be looking for new ways to exploit the situation

 

Collaborating with external partners

DO DON'T

Provide details of your collaboration with external partners, including the measures taken

Sign up to partnerships or collaborations, expecting for them to resolve the problem for you  

Collaborate within your sector and share good practice 

Treat the statement as a competition or a trade secret  

Seek to collaborate with organisations working in different sectors that can help you manage modern slavery risks – for example Electronics Watch who provides intelligence, collaboration and support about working conditions in factories that assemble ICT

Think you can combat Modern Slavery on your own, pooling resources and intelligence will often be required

 

Measuring effectiveness and planning for the future

DO DON'T

Report on how you will measure effectiveness and who is responsible for this measurement 

State the procedures have been reviewed without indicating the assessment and impact they had 

Provide information on existing Key Performance Indicators (KPIs) 

Make ambiguous and general commitments for the coming years   

Ensure KPIs are Modern Slavery related, including responsible procurement KPIs

List commitments which are not directly relevant  

Track progress at short, medium and long term, and allow for substantive measurement

Fail to assess and report on the effectiveness of measures undertaken   

Review your aims, goals and KPIs annually, with distinct future goals

Reproduce the same KPIs year on year without measuring their effectiveness

Be honest, if you’ve not had much success it’s fine to be upfront about this whilst striving to improve in the future

Be afraid of publishing a lack of progress or hide setbacks

 

Training and capacity

DO DON'T

Provide Modern Slavery specific training which is relevant to your organisation 

Cite training unrelated to Modern Slavery in your statement or provide training which is not relevant to your work

Provide training to all staff, including refreshers and new courses

Reduce Modern Slavery training to induction processes for new staff

Provide targeted Modern Slavery supply chain and contract management training for relevant staff, especially to procurement teams, contract managers, trading standards, compliance, legal and finance teams 

Use a one fits all approach 

Use external and internal training

Outsource all training responsibilities to consultants

 

Credits

This information was produced by Dr. Olga Martin-Ortega and Anna Gorna of the University of Greenwich

Further resources can be found on the LGAs Modern Slavery in the Supply Chain hub: www.local.gov.uk/topics/community-safety/modern-slavery/supply-chains