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MSA whistleblowing mechanism (revised)
Does the company describe a grievance mechanism to facilitate whistle-blowing or the reporting of suspected incidents of slavery or trafficking?
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About the data

Businesses should provide a hotline or other grievance mechanism so that anyone part of or witness to their operations and supply chains may report or flag suspected incidents of slavey or trafficking. As part of business’ responsibility to respect worker’s rights, those affected by modern slavery and those witnessing violations in any part of a company’s operations should be able to freely report incidents. These mechanisms should be clear and transparent, and any incidents should be recorded and monitored. 

For further information on grievance mechanisms please refer to the Home Office Guidance, pp. 33 or the CORE Guidance, pp. 19.

Does the company provide a hotline or reporting mechanism where grievances or suspected incidents of slavery or trafficking can be reported for direct employees and/or supply chains workers?

A whistleblowing mechanisms may include:

  1. A reporting line or hotline that workers can call (reporting managed by third parties, or reporting platforms like a 'Speak Up' tool, not policy, fall in this category too) 

  2. Whistleblower protections for employees so they will not be penalised if they report modern slavery cases (mention of any kind of protection is sufficient e.g. "we ensure that anyone raising such concern will not suffer dismissal, disciplinary action, threats or other unfavourable treatment as a result" ). If the disclosure specifies that grievances can be reported anonymously or confidentially, that also is sufficient for this answer option. Key words: Retaliation, repercussions, fear, reprisal, detriment 

  3. An employee or independent focal point to whom reports can be made. A focal point is in place permanently. If the statement states that reports of violations can be shared with auditors or other personnel operating at the company on a temporary basis, they would not qualify as a focal point.

A direct employee is someone who is working directly for the company either in the company head office or in regional offices.

supply chain worker is someone who is employed by contractors or sub-contractors further down the supply chain.

For many companies the risk of forced labour is much greater within their supply chain rather than in their own operations - as such the provision of a mechanism that extends to workers within the company’s supply chain is regarded as a positive step.

Please select as many mechanisms as apply.

NOTE: 'Speak Up' or any other policy can be sufficient to meet the answer 'Hotline, Email, Contact Form' if details are provided specifying how workers' concerns can be raised. If it is not explicitly stated, it cannot be assumed.

Where there is no mention in the statement of who the mechanism applies to, please assume it applies only to direct employees.

If the business indicates it is developing a whistleblowing or grievance mechanism or planning to implement one in the future, please indicate “In Development” and again give details in the comments section.

Please select "No" if no whistleblowing mechanism is described in the statement.

For each value, please include a comment that copies relevant information from the statement. If the policy that you wish to include is not listed, please add a comment and flag the section for review.

Nikon, MSA Statement 2020, p. 2

"For Nikon employees, we have internal as well as regional or local external hotline(s) by which they are ableto report if they become aware of an actual or potential violation of the Nikon Code of Conduct. Our employees can use the hotline(s) anonymously.".


"We strongly encourage all our workers and business partners to report any concerns related to our activities or activities within our supply chains. Our whistleblowing policy ensures that all workers know that they can raise concerns about how workers are being treated, or practices within our business or supply chain. This includes any circumstances that may give rise to an enhanced risk of modern slavery and human trafficking. This policy is designed to make it easy for workers to make disclosures, without fear of reprisals." (page 3)

Uk Green Investment Bank Ltd, MSA Statement 2018, P. 2

"Macquarie staff and external parties can confidentially report concerns about improper conduct by Macquarie or suppliers to the Integrity Office, an internally independent and confidential function that oversees Macquarie’s Whistleblower Program. In 2018, there were no reports of slavery or trafficking through the Whistleblower Program.".


* Note on choosing the Year of your answer

Read the MSA Statement carefully to find out what year it covers.

When a statement is referring to a Financial Year (FY) ending in Q1 or early Q2, it should be labeled with the previous year. Example:

  • Statement for FY2018/19 ending in April 2019 = 2018
  • Statement for FY2018/19 ending in May 2019 (or later) = 2019
Value Type
Hotline, Email, Contact Form (direct employees)
Hotline, Email, Contact Form (supply chain workers)
Whistleblower protection (direct employees)
Whistleblower protection (supply chain workers)
Focal Point (direct employees)
Focal Point (supply chain workers)
In Development (direct employees)
In Development (supply chain workers)
Research Policy
Community Assessed
Report Type
Modern Slavery Statement
Katharine Bryant
Samantha Wolk
Francisca Sassetti