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Businesses are facing a huge global challenge to comply with the obligations introduced by the Modern Slavery Act 2015. On 6th October 2016, the LexisNexis In-house Advisory Board met to discuss modern slavery and its relationship to supply chain management, including the importance of risk assessment and due diligence.
The session was facilitated by Clive Davies, Senior Counsel at Fujitsu Services, and Colleen Theron, a modern slavery expert and environmental, business and human rights lawyer and consultant. It opened with an introduction to the Modern Slavery Act 2015
and supply chains. Supply chains were identified as incredibly difficult to manage due to their potential size – when faced with compliance, companies may panic as they simply don’t know where to start.
Slavery and human trafficking statements
The Modern Slavery Act requires certain organisations to develop a statement each year. There is concern that these are likely to be a gloss of what policies are in place without in-depth risk assessment. It isn’t just about producing the statement,
it also involves appropriate engagement, training and good reporting.
Clive Davies shared with the Board how Fujitsu prepared a global risk analysis to geographically map where their suppliers were and to see how those locations ranked in the Global Slavery Index. Without such a process, companies don’t know where
their products are and therefore cannot understand the risk.
The approach to due diligence that a company takes should always be determined by risk analysis. The Board discussed several key questions:
Whistleblowing presents challenges. It may not be appropriate in the modern slavery context because there is a real fear for the victims. Some organisations are working closely with NGOs in the area and implementing whistleblowing processes through those
Engaging the business
Modern slavery compliance requires the buy-in of the whole business. To engage the business, the approach should highlight how compliance helps both people and the company’s reputation. It needs to be integral to the values of a company in the same
way that corporate social responsibility is.
Read a full summary of the LexisNexis In-house Advisory Board meeting here.
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