Establishing effective policies to combat modern slavery is listed as one potential component of a modern slavery statement within the UK Modern Slavery Act and is recommended by the Home Office guidance accompanying it. Clear organisational policies help to set the tone in assessing, preventing and mitigating the risk of, and working to influence and remedy, modern slavery in organisations and their own operations and supply chains. It also helps to demonstrate a company’s commitment to tackling modern slavery.
For further information on policies use the Home Office Guidance, pp. 28-30
Does the company’s statement detail clear, organisational modern slavery policies that apply to their direct and/or beyond tier 1 supply chain? These policies must be explicit and go beyond vague statements of intended actions. Often these policies can be found at the beginning of a statement.
Direct supply chains can also be referred to as tier 1 supply chains and consequently beyond tier 1 includes all players of the supply chain that are not directly tied to the company.
Policies can include:
requiring all suppliers and contractors to comply with local and international laws (including the UN Guiding Principles, ILO standards, or International Conventions), and company’s policies,
prohibiting contractors or suppliers from using modern slavery, forced labour, involuntary labour, debt bondage or human trafficking,
prohibiting contractors or suppliers from using child labour,
including clauses on forced labour in Codes of Conduct or Supplier Codes,
requiring contracts to include clauses on forced labour in supply chains,
requiring all suppliers and contractors to respect labour rights more generally, such as paying living wages, or allowing freedom of association,
prohibiting all suppliers and contractors to charge employees fees as part of their recruitment,
requiring all suppliers and contractors to provide additional protection for migrant workers, or
requiring suppliers to produce their own statement on modern slavery and forced labour.
Please note this metric refers to organisational policies that are clear and explicitly tackle and prevent modern slavery. It does not measure supplier engagement such as supplier audits, questionnaires, site visits, etc., this is measured by the metrics: 'MSA risk assessment' and ‘MSA risk management’
Please select as many policies as apply. Distinguish whether these policies adhere to “direct” or “Tier 1” suppliers or “Tier 2” or “beyond Tier 1” or “in-direct” suppliers. If it is not specifically mentioned which supply chain tiers these policies apply to, please assume they cover direct suppliers only.
If no such policy exists, then please select “No”.
If the business indicates it is developing a modern slavery supply chain policy or is planning to implement one in the future, please indicate “In Development”.
For each value, please include a comment that copies relevant information from the statement and page numbers of where you found the information in the statement. If the policy that you wish to include is not listed among the possible metric answers, please add a comment and flag the section for review.
* 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, it should be labeled with the previous year.
Statement for FY2018/19 ending in March 2019 = 2018
Statement for FY2018/19 ending in April 2019 (or later) = 2019
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