Auditing suppliers—modern slavery and human trafficking
Auditing suppliers—modern slavery and human trafficking

The following Practice Compliance guidance note provides comprehensive and up to date legal information covering:

  • Auditing suppliers—modern slavery and human trafficking
  • Who should conduct the audit?
  • Audit process
  • Preparing for an audit
  • Key steps in the audit
  • Following up the audit

This Practice Note describes what a good modern slavery and human trafficking supplier audit process looks like and provides guidance on who should conduct audits, how to prepare for and carry out an audit, and how audits should be followed up.

Who should conduct the audit?

Whether you use internal auditors or an external firm, or a combination of the two, the auditor or team of auditors must be trained professionals who have in-depth knowledge of the risk factors.

They must have the ability to identify and investigate labour abuses, sometimes in very challenging environments.

Key things to think about if you’re looking at external auditors include:

  1. the tools and approaches being used, eg they don’t just look at current labour conditions, they also focus on recruitment

  2. reviewing their documents and records

  3. the amount of focus they put on worker interviews and the time they allow for them

Audit process

Audits should be framed to uncover any indicators of slavery or human trafficking.

Process is as important as content.

A good audit process involves checking information received against several different sources, eg information obtained from:

  1. management interviews

  2. worker interviews

  3. workplace observations, and

  4. a review of documents and records

But the first element of the process is preparation.

Preparing for an audit

Consent

To undertake the audit you’ll need your supplier’s consent to access the