Today there is an ever-growing focus on supply chain management due diligence in the fields of ESG, forced labour, and modern slavery. It’s a significant area of compliance for most businesses with regulatory activity and litigation on the rise. Increasingly organisations are being asked about their work in this area too – by customers, by employees and by investors.
Cordery has worked on modern slavery and supply chain issues right from the start. We were involved in the consultation process for the UK’s ground-breaking modern slavery law and we’ve helped businesses large and small with their compliance programmes, statements and due diligence.
It’s an area of constant change. The EU has released guidance about forced labour in business operations and supply chains and there are plans to introduce legally-binding EU rules on corporate supply chain due diligence on human rights & environmental and governance issues. There’s a planned ban on imports of forced labour-related products too.
In addition, the number of countries both inside and outside the EU introducing their own supply chain due diligence laws is rapidly evolving with France and Germany as two prominent European examples. And it’s not just about legislation either: in the UK there has been a Parliamentary enquiry into supply chains in Xianjing in China; activism is shining a spotlight on modern slavery issues including through litigation; and, business partners are also raising compliance questions such as through procurement processes.
In the UK the Modern Slavery Act 2015 is targeted at combatting modern slavery and human trafficking. It includes rules on supply chain compliance obligations that require businesses with a turnover of over UK£36 million (around $50 million) to issue a detailed annual modern statement to explain what they have been doing to ensure that there is no modern slavery in their business and supply chains. This also applies to organizations based outside the UK selling goods and services into the UK. To make sure that you’re on the right track Cordery can help you with the following:
- Modern Slavery Statements – we can review these and guide you on best practice. Bear in mind that the statement is about what you’ve done in a given year, i.e. it is not aspirational, or to put it another way, no greenwashing!
- Modern Slavery Policy – we can create a stand-alone policy and/or review any existing internal materials
- Risk assessment, due diligence, KPIs and audits – we can create questionnaires for you to provide to your suppliers along with guidance materials to help you and advise you on how best to handle these processes
- Contracts and Terms & Conditions – we can create or review contractual clauses or T&Cs that address modern slavery concerns
- The UK Parliamentary enquiry into supply-chains and Xinjiang in China – the full outcome of this is still expected which we can advise you about as things develop
- The UK Modern Slavery Register – this is currently voluntary (but is expected to become mandatory)
- Training – we can do this for a group (e.g. the procurement team) or one-on-one (e.g. for the director who has to sign the modern slavery statement). We can also make a customised film (e.g. for on-boarding – see our film on spotting the signs of modern slavery here https://www.corderycompliance.com/spotting-the-signs-of-modern-slavery/)
Recent projects include:
- Advising a client in connection with its appearance before a UK Parliamentary enquiry into supply chains, due diligence and forced labour
- Advising a US technology business in connection with an approach from UK Government relating to its entry in the Modern Slavery Register
- Advising a household name logistics company on the likelihood of specific import laws being used to stop the free movement of goods
- Helping a Swiss based healthcare business look at its modern slavery obligations in light of greater transparency obligations imposed by purchasers of its products
- Advising a US-based entertainment business on the compliance obligations of a recently acquired subsidiary
- Advising a global energy company regarding issues with the supply of solar panels and their sourcing in China
- Helping a global fashion group in connection with approaches from UK Government
- Advising clients in connection with statements to meet their Australian and UK disclosure obligations
- Training organisations large and small on slavery & forced labour compliance
- Reviewing online training & suggesting improvements
- Advice to a leading fashion group on their modern slavery compliance strategy across all of their brands
- Advising a leading pharmaceutical business on prevention of slavery in its supply chain
To discuss how we can help please contact:
M +44 (0)7775 788 795
Get in touch here.
In this short video, Cordery’s Jonathan Armstrong and André Bywater review The Modern Slavery Act 2015 following the UK Government publishing guidance about this new compliance obligation.