Mitigation actions may include:

• Participating in or launching industry initiatives (e.g. UN Global Compact, or Finance Against Slavery and Trafficking Initiative), or by providing financial support to such initiatives;
• Requiring suppliers and third-party entities to comply with internal, regional, or international policies or labor laws;
• Requiring employees, suppliers, or other stakeholders to follow training sessions on modern slavery;
• Adopting or updating internal modern slavery-related policies, frameworks or standards, for instance:
  • Adopting formal processes used to identify and assess modern slavery risks. These processes may include:
    • Conducting desk research by reviewing secondary sources of information (e.g. reports from international organizations, frameworks such as the UN Guiding Principles, or research papers and articles on modern slavery) or by reviewing external expert advisers’ inputs;
    • Utilizing risk management tools or software (e.g. SEDEX);
    • Conducting risk-based questionnaires, surveys, or interviews with employees, suppliers, or other stakeholders;
    • Auditing, screening, or directly engaging with employees, suppliers, or other stakeholders.
  • Committing to paying all employees, migrant workers, temporary workers, and third-party workers a “living wage”, to support their freedom of association (or unionization), or to support collective bargaining;
  • Adopting a code of conduct or code of ethics that relates to combatting or preventing modern slavery and forced labour practices; 110○ Incorporating provisions for onboarding and engaging with suppliers, including contract clauses and requirements, and extending the code of conduct to cover suppliers;
  • Enforcing responsible recruitment of workers (e.g., by not allowing the payment of recruitment fees by workers, or by not withholding part of their compensation for housing or licensing costs);
  • Implementing responsible procurement practices when establishing new supply chains (e.g., no excessive pressure on lead times for products or services they source);
  • Having a zero-tolerance policy that would force the entity to take action regarding threats, regarding intimidation and attacks against human rights defenders, or regarding modern slavery cases tied to their suppliers;
  • Establishing a whistleblowing policy that encourages and safeguards workers, employees, suppliers, or other stakeholders when reporting concerns;
  • Ensuring the application of these policies or frameworks by having an executive or board member participate in their elaboration or in oversight committees.

Notes:

• Vague language stating that the reporting entity has “zero tolerance” towards modern slavery without mentioning a policy in this regard, or that it “is committed to fight” modern slavery is very common. However, such declarations are not evidence of risk mitigation by themselves. These declarations should be linked with an actual company policy or linked to industrial initiatives or certifications frameworks. If no other relevant information is found, the correct label in statements containing only such declarations is NO.
• Not all policies adopted by an entity may be relevant to modern slavery. If a policy does not explicitly cover modern slavery (which includes forced labour, human trafficking, child labour, etc.), then the entity should itself detail why it is relevant in this context for it to be considered evidence of a risk mitigation action. Only extract policy-related sentences if the policy is truly linked to modern slavery practices somewhere in the statement.