Modern slavery statements
The deadline is looming
Technical blog by Liz Sandwith, chief professional practice advisor | 17 January 2017
As we approach the end of financial year there is now another task facing a significant number of organisations which is the drafting of the modern slavery statement which talks to how the organisation has complied with the legislation. According to the Home Office’s guidance large employers must publish a modern slavery statement within six months of the organisation’s financial year end for each financial year ending on or after 31 March 2016.
Personnel Today has set out eight steps for HR professionals to follow when drafting their statements. The steps are also areas of focus and interest for internal auditors. They look at whether the organisation has the evidence to support the statements made, and is the evidence reliable, useful, sufficient and trustworthy (to use internal audit's 'RUST' mnemonic).
Eight steps
- Reiterate commitment to tackling modern slavery
- Explain your organisational structure and supply chains
- Set out who has responsibility for anti-slavery initiatives in your organisation
- Reference to relevant local policies and procedures
- State what due diligence of suppliers is carried out
- Provide an overview of key performance indicators e.g. requiring staff to complete training on modern slavery; developing a system for supply chain verification; and reviewing their existing supply chains.
- Explain how your organisation trains staff on anti-slavery measures
- Flag up any awareness-raising programme
Internal auditors, we need to be stepping up to the plate, ensuring that before any statement is published it has been subjected to rigorous scrutiny which is something we ought to do for the organisation. Failure to ensure that the statement has been appropriately reviewed may lead to reputational risk / damage if it is subsequently found to be inaccurate or incorrect.
The Chartered IIA is currently drafting technical guidance on how to audit the modern slavery statements, so watch this space!
Further information and guidance
Examples of statements:
There are already some statements on the website which provide a useful source of information
- Ford Motor Company
- The Christie NHS Foundation
- AFE Group – the company has its headquarters in the UK but has 15 locations worldwide, including UK, France, UAE, China and Australia
- McMullen & Sons Limited – they use the following as key performance indicators - Completion of House Audits by Area Managers and Business Development Managers; Use of labour monitoring and payroll systems; and Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.
Although the UK government does not specify exactly what should be included in this statement, Section 54 of the Modern Slavery Act recommends including the following information:
- The total annual turnover of the organisation
- The organisation’s structure and all its supply chain
- The human trafficking and slavery policies of the organisation
- The company’s due diligence procedure regarding human trafficking and slavery in its supply chain
- The steps it is taking to diminish the risk of human trafficking and slavery in its supply chain. Identifying where the biggest risk lies will help your organisation achieve this.
- The efficiency and success in guaranteeing that human trafficking and slavery is not taking place in the organisation’s supply chain. There should be effective performance indicators in place to measure this.
- The human trafficking and slavery training available to the organisation’s staff
PwC provides guidance on who should approve the statement.
