About the data
Criteria 5: Assessing the effectiveness of actions
The reporting entity should describe in its statement how it assesses the effectiveness of actions taken to mitigate risks as well as to remediate modern slavery cases. This is important to ensure that the entity knows whether these actions are actually helping combat modern slavery.
Methodology
The supporting text for this criteria should relate to the examination of whether the measures and processes implemented by the reporting entity are successful in achieving their intended goals related to mitigating risks and remediating cases of modern slavery. In practical terms, this means evaluating how well the company's strategies and initiatives are performing in practice. This assessment often involves tracking key performance indicators, monitoring the outcomes of risk mitigation efforts, seeking feedback from stakeholders, and conducting regular reviews to ensure that the actions in place align with the company's commitment to address modern slavery.
Specifically, assessing the effectiveness of actions can be accomplished by:
- Examining or revising action plans or policies, such as by forming a review committee or conducting annual assessments, to ensure that:
- they remain up to date, particularly when operating in high-risk countries, regions, or industries;
- they adhere to the internal organization guidelines regarding application deadlines or in terms of uniformity in their application; or
- they have the intended results (e.g. in terms of dissuasive power).
- Setting up a feedback process between key departments (or across owned or controlled entities) to facilitate regular engagement and communication among procurement, human resource management, and legal teams;
- Engaging with industry groups, external auditors, trusted NGOs, or stakeholders (such as the workers themselves) to provide feedback and/or conduct an independent review of actions;
- Implementing internal checks to evaluate the efficiency of the actions of risk identification, mitigation or remediation processes;
- Reviewing trends in reported modern slavery cases through grievance or whistleblowing mechanisms and evaluating the handling of these cases;
- Reporting and monitoring Key Performance Indicators (KPIs) that measure the effectiveness of actions, such as:
- The number of contracts in which modern slavery cases were identified;
- The number of trainings delivered to employees, suppliers, or other stakeholders;
- The awareness of employees, suppliers, or other stakeholders towards modern slavery as measured through polls;
- The number of initiatives taken to enhance suppliers' capacity to respond to modern slavery risks;
- The number of filed grievances;
- The resolution rates of reports filed through grievance or whistleblowing mechanisms;
- The number of completed audits;
- The number of visits in facilities operated by the reporting entity, by one of its owned or controlled entities, or by a third-party;
- The number of assigned and completed corrective action plans;
- The number of contracts canceled due to identified modern slavery cases;
- The number of identified modern slavery incidents.
Note: entities will often state that they "improved their modern slavery risk mitigation" over a reporting period, but this is not useful information for this question. Supporting text for this question should instead detail how the reporting entity determined that its actions were effective or not effective. For example, if the reporting entity stated that it "improved its modern slavery risk mitigation actions following a comprehensive review process", then it can be considered relevant for this question.
