pg. 15

"b) Engaging with suppliers

This section looks at various due diligence measures adopted by local authorities and ways in which they engage their suppliers. There is a noticeable increase in the use of the Standard Selection Questionnaire (SSQ) provided by the Crown Commercial Service, or at least some variation thereof. Whilst using questionnaires to gather information on supplier’s compliance with their MSA 2015 obligations is a good practice, and sends a powerful message of commitment by local authorities, it is important to remember that this kind of selfcertification has its limitations.

The SSQ does not allow to compile detailed enough information to ensure that abuses are not present in supply chains, or whether suppliers are themselves exercising due diligence in their own supply chains. The SSQ operates on a on the basis of selfcertification. As in previous years, Councils continue to request that suppliers selfcertify that no modern slavery is taking place in their supply chains. Overall, it is a low effort due diligence measure, and as emphasised in or first Research Report, it is likely to be ineffective due to the lack of proper checks and monitoring. Moreover, if questions to suppliers are limited to whether they comply with their MSA s.54 obligations, smaller businesses will not be questioned on their efforts to combat modern slavery as they do not meet the £36 million reporting threshold."

pg. 32

"Ensure that you have functioning and responsible procurement and contract management due diligence procedures to minimise risks of modern slavery taking place within domestic and global supply chains. For example:

• referrals, site visits and spot checks • contractual provisions and contract monitoring and management • asking for suppliers to provide their own due diligence of their subcontractors and supply chains • use online modern slavery risk identification and management tool such as the government’s Modern Slavery Assessment Tool (MSAT)"