Modern Slavery Statement
Discussion
Got a client asking for our modern slavery statement. They weren't too happy when we told them we didn't have one as our turnover is considerably less than £36 million which is the point where a company is legally required to have one .
The woman we are talking to isn't our regular contact and is insisting we have to supply one and they can't do business with us without one. They aren't worth that much to us and I am thinking of asking them to raise a P/O to supply one. If they want a proper statement we have to chase down all our suppliers (around 40) and get their modern slavery statements (if they have one) . I suspect it could easily take a week just to gather all the statements together.
Anyone have any experience of this type of thing?
The woman we are talking to isn't our regular contact and is insisting we have to supply one and they can't do business with us without one. They aren't worth that much to us and I am thinking of asking them to raise a P/O to supply one. If they want a proper statement we have to chase down all our suppliers (around 40) and get their modern slavery statements (if they have one) . I suspect it could easily take a week just to gather all the statements together.
Anyone have any experience of this type of thing?
Lol its the biggest load of old b
ks ever, I don't know of any company in the UK that would consider using forced labour. Dont get me wrong it is an issue that needs addressing but the £36m T/O is the wrong place to start, if there is a problem it is in car washes and nail bars not PLCs.
We have to audit our supply chain for our public sector contracts... it is literally a statement, they are all very similar, here is ours, stolen from someplace. A number of our supply chain use a very similar statement that may or may not have been sent to them to fill in...
Its a box ticking exercise, we have never been quizzed on it. To be honest normal employment procedures will ensure you do not employ forced labour.
UK Modern Slavery Act Transparency Statement:
This statement outlines the steps that Insert name here is taking under Section 54 of the Modern Slavery Act 2015 (“Act”) to reasonably ensure that modern slavery is not occurring within our business and supply chains.
The Act defines modern slavery as slavery; servitude and forced or compulsory labour; and human trafficking.
Insert name here is committed to conducting all business affairs lawfully and with integrity. One of our key principles is not only to strive for compliance with all laws and regulations, but also to treat people with honesty, dignity and respect. We hire people who share our values and beliefs and who are fully committed to this principle. Insert name here compliance and ethics expectations are set out in our Code of Conduct, and apply to all officers, directors, and employees.
We rely on our suppliers sharing our values and complying with all laws at all times. We expect our business partners to treat people with dignity and respect and not to engage in practices associated with forced labour, even if not illegal in their locations. To ensure that modern slavery is not occurring within our supply chains, we make reasonable efforts to know our suppliers and their work practices, including their reputations for legal compliance and respect for human rights. We will act to discontinue relationships with those suppliers and other third parties who fail to meet our high standards for lawful and ethical conduct.
To help ensure that modern slavery is not taking place in our supply chains Insert name here is working to introduce into relevant supply contracts clauses that will require suppliers to not use any form of forced labour and give Insert name here the right to terminate business relations if such obligation is not respected. Insert name here is also working to improve its ability to audit its suppliers on this particular requirement.
In addition to these steps, Insert name here offers a Compliance & Ethics Helpline which provides employees, customers, suppliers and members of the general public with a mechanism, including on an anonymous basis (where allowed by law), to report concerns about potential breaches of Insert name here's Code of Conduct, a Insert name here policy, or the law.
This statement was approved by the Board of Directors of Insert name here, Insert name here and Insert name here on date.
ks ever, I don't know of any company in the UK that would consider using forced labour. Dont get me wrong it is an issue that needs addressing but the £36m T/O is the wrong place to start, if there is a problem it is in car washes and nail bars not PLCs. We have to audit our supply chain for our public sector contracts... it is literally a statement, they are all very similar, here is ours, stolen from someplace. A number of our supply chain use a very similar statement that may or may not have been sent to them to fill in...
Its a box ticking exercise, we have never been quizzed on it. To be honest normal employment procedures will ensure you do not employ forced labour.
UK Modern Slavery Act Transparency Statement:
This statement outlines the steps that Insert name here is taking under Section 54 of the Modern Slavery Act 2015 (“Act”) to reasonably ensure that modern slavery is not occurring within our business and supply chains.
The Act defines modern slavery as slavery; servitude and forced or compulsory labour; and human trafficking.
Insert name here is committed to conducting all business affairs lawfully and with integrity. One of our key principles is not only to strive for compliance with all laws and regulations, but also to treat people with honesty, dignity and respect. We hire people who share our values and beliefs and who are fully committed to this principle. Insert name here compliance and ethics expectations are set out in our Code of Conduct, and apply to all officers, directors, and employees.
We rely on our suppliers sharing our values and complying with all laws at all times. We expect our business partners to treat people with dignity and respect and not to engage in practices associated with forced labour, even if not illegal in their locations. To ensure that modern slavery is not occurring within our supply chains, we make reasonable efforts to know our suppliers and their work practices, including their reputations for legal compliance and respect for human rights. We will act to discontinue relationships with those suppliers and other third parties who fail to meet our high standards for lawful and ethical conduct.
To help ensure that modern slavery is not taking place in our supply chains Insert name here is working to introduce into relevant supply contracts clauses that will require suppliers to not use any form of forced labour and give Insert name here the right to terminate business relations if such obligation is not respected. Insert name here is also working to improve its ability to audit its suppliers on this particular requirement.
In addition to these steps, Insert name here offers a Compliance & Ethics Helpline which provides employees, customers, suppliers and members of the general public with a mechanism, including on an anonymous basis (where allowed by law), to report concerns about potential breaches of Insert name here's Code of Conduct, a Insert name here policy, or the law.
This statement was approved by the Board of Directors of Insert name here, Insert name here and Insert name here on date.
Edited by nikaiyo2 on Wednesday 8th November 10:50
Have you seen what their Transparency in Supply Chains statement actually says about the steps they take to ensure there is no modern slavery in their supply chains? That might be the starting point for trying to have a sensible conversation with them. A blanket policy of asking all suppliers to supply a TISC statement is daft, and unrealistic - will they ask for one from the newsagent who supplies the newspapers and magazines in their reception area?
It isn't necessarily so pointless. Let me give a real world example with at least some relevance to PH - petrol stations:
Let's say I have 10 petrol stations. I don't want to direct manage them myself, so put in self-employed contractors to run them. The contractor is responsible for employing the staff. I want BigOilCo. to supply my sites. No problem says BigOilCo, I see your credit is good, we will supply you. All good - my petrol stations are all branded BigOilCo. Six months later, OMG fire at one of my petrol stations, member of staff killed. Turns out he was an illegal immigrant, untrained, and had been working 16 hours a day in return for the share of a bunk bed and some basic food and £20 a week. Oh look, it's BigOilCo's name all over the papers. Then mine. Then the contractors.
Yes, if only lip service (as outlined above) is paid to the statement then it will still happen. However, if I'd taken a professional approach to my responsibilities I would have found out how my contractor was 'paying' his staff and potentially avoided the catastrophe.
That's why companies up and down supply chains should be taking it seriously.
Let's say I have 10 petrol stations. I don't want to direct manage them myself, so put in self-employed contractors to run them. The contractor is responsible for employing the staff. I want BigOilCo. to supply my sites. No problem says BigOilCo, I see your credit is good, we will supply you. All good - my petrol stations are all branded BigOilCo. Six months later, OMG fire at one of my petrol stations, member of staff killed. Turns out he was an illegal immigrant, untrained, and had been working 16 hours a day in return for the share of a bunk bed and some basic food and £20 a week. Oh look, it's BigOilCo's name all over the papers. Then mine. Then the contractors.
Yes, if only lip service (as outlined above) is paid to the statement then it will still happen. However, if I'd taken a professional approach to my responsibilities I would have found out how my contractor was 'paying' his staff and potentially avoided the catastrophe.
That's why companies up and down supply chains should be taking it seriously.
nikaiyo2 said:
Lol its the biggest load of old bks ever, I don't know of any company in the UK that would consider using forced labour. Dont get me wrong it is an issue that needs addressing but the £36m T/O is the wrong place to start, if there is a problem it is in car washes and nail bars not PLCs.
So you don't know of any company in the UK that would consider using forced labour - yet quote two market sectors where there is a chance that exactly that is happening!ks ever, I don't know of any company in the UK that would consider using forced labour. Dont get me wrong it is an issue that needs addressing but the £36m T/O is the wrong place to start, if there is a problem it is in car washes and nail bars not PLCs. It is a very valid need - for companies to understand how they are / are not influencing or helping to drive forced labour - whether it is the company polo shirts that are bought from the cheapest supplier - who brings in the clothing from a company in the far east where forced labour is used - to directly doing it yourself in a company - the reality is that most big companies in the UK may well unintentionally have forced labour in their supply chain and one of the ways to stop it is to put the obligation onto the recipients - when you start to unpack the supply chain for large companies, there is a complete web of companies supplying them - and it is a supply chain where cost is a major factor - so there will be points in that supply chain where cost means that a supplier, (or a supplier to a supplier to a supplier) will do what they can to gain the business - cut costs and staffing is a key cost centre...
yes, the large company needs to do this work to explore their supply chain, but any company wanting to be a supplier into a larger company needs to now take hold of their responsibility to demonstrate with clarity their own position... and I suspect, and would hope, that the day will be coming when the large corporations will need to demonstrate that they have actually audited their supply chain for this purpose...
very difficult to stop the sweatshops - much easier to penalise the big corporations who ultimately fund them...
akirk said:
So you don't know of any company in the UK that would consider using forced labour - yet quote two market sectors where there is a chance that exactly that is happening!
It is a very valid need - for companies to understand how they are / are not influencing or helping to drive forced labour - whether it is the company polo shirts that are bought from the cheapest supplier - who brings in the clothing from a company in the far east where forced labour is used - to directly doing it yourself in a company - the reality is that most big companies in the UK may well unintentionally have forced labour in their supply chain and one of the ways to stop it is to put the obligation onto the recipients - when you start to unpack the supply chain for large companies, there is a complete web of companies supplying them - and it is a supply chain where cost is a major factor - so there will be points in that supply chain where cost means that a supplier, (or a supplier to a supplier to a supplier) will do what they can to gain the business - cut costs and staffing is a key cost centre...
yes, the large company needs to do this work to explore their supply chain, but any company wanting to be a supplier into a larger company needs to now take hold of their responsibility to demonstrate with clarity their own position... and I suspect, and would hope, that the day will be coming when the large corporations will need to demonstrate that they have actually audited their supply chain for this purpose...
very difficult to stop the sweatshops - much easier to penalise the big corporations who ultimately fund them...
You make a valid point... I also think I was a little flippant in my post, our supply chain is 95% multinationals, who have their own slavery statements, so I have always regarded it as relating directly to our business. It is a very valid need - for companies to understand how they are / are not influencing or helping to drive forced labour - whether it is the company polo shirts that are bought from the cheapest supplier - who brings in the clothing from a company in the far east where forced labour is used - to directly doing it yourself in a company - the reality is that most big companies in the UK may well unintentionally have forced labour in their supply chain and one of the ways to stop it is to put the obligation onto the recipients - when you start to unpack the supply chain for large companies, there is a complete web of companies supplying them - and it is a supply chain where cost is a major factor - so there will be points in that supply chain where cost means that a supplier, (or a supplier to a supplier to a supplier) will do what they can to gain the business - cut costs and staffing is a key cost centre...
yes, the large company needs to do this work to explore their supply chain, but any company wanting to be a supplier into a larger company needs to now take hold of their responsibility to demonstrate with clarity their own position... and I suspect, and would hope, that the day will be coming when the large corporations will need to demonstrate that they have actually audited their supply chain for this purpose...
very difficult to stop the sweatshops - much easier to penalise the big corporations who ultimately fund them...
I agree with your sentiments on global supply chains, but think actually we should be addressing the issues closer to home 1st.
There are huge issues with forced or coerced labour here, the business who have filled out statements are by and large business who act in responsible manner and are not the real problem, the real problem is the bushiness who are set up to exploit this labour situation.
I'd give them the following -
In the normal course of events, we never use "modern slaves". However, now and then we do make use of sole "old fashioned" ones. Our policy is as follows -
we ensure that each slave's chains are never attached too tightly and good circulation is maintained
we only use whips when the work becomes rather strenuous and they start slacking
we allow each slave one pint of weak beer (in line with Egyptian protocols) on completion of the daily 16 hour shift
if a slave tries to escape, we will use force to stop him/her If a slave is killed in an escape attempt, we will require compensation from the slave broker
sleeping accommodation will be provided. A slave is entitled to a mattress after five years service
slaves will be sold off at then end of their useful working lives and when they have been fully depreciated
We trust you find the above helpful and in accordance with the current regulation.
Yours faithfully
Ramses II
Dated 1500BC
In the normal course of events, we never use "modern slaves". However, now and then we do make use of sole "old fashioned" ones. Our policy is as follows -
we ensure that each slave's chains are never attached too tightly and good circulation is maintained
we only use whips when the work becomes rather strenuous and they start slacking
we allow each slave one pint of weak beer (in line with Egyptian protocols) on completion of the daily 16 hour shift
if a slave tries to escape, we will use force to stop him/her If a slave is killed in an escape attempt, we will require compensation from the slave broker
sleeping accommodation will be provided. A slave is entitled to a mattress after five years service
slaves will be sold off at then end of their useful working lives and when they have been fully depreciated
We trust you find the above helpful and in accordance with the current regulation.
Yours faithfully
Ramses II
Dated 1500BC
nikaiyo2 said:
You make a valid point... I also think I was a little flippant in my post, our supply chain is 95% multinationals, who have their own slavery statements, so I have always regarded it as relating directly to our business.
I agree with your sentiments on global supply chains, but think actually we should be addressing the issues closer to home 1st.
There are huge issues with forced or coerced labour here, the business who have filled out statements are by and large business who act in responsible manner and are not the real problem, the real problem is the bushiness who are set up to exploit this labour situation.
very true - hence my comment about auditing - ultimately those companies who exploit labour are usually in the B2B sector, e.g. rag trade, though some exist in B2C - it is the B2B businesses which are harder for the authorities to tackle, so getting the big corporates to deal with it could be very effective - ultimately the wealth created by exploiting labour ends up in the big business - so tackle that...I agree with your sentiments on global supply chains, but think actually we should be addressing the issues closer to home 1st.
There are huge issues with forced or coerced labour here, the business who have filled out statements are by and large business who act in responsible manner and are not the real problem, the real problem is the bushiness who are set up to exploit this labour situation.
Roman Rhodes said:
It isn't necessarily so pointless. Let me give a real world example with at least some relevance to PH - petrol stations:
Let's say I have 10 petrol stations. I don't want to direct manage them myself, so put in self-employed contractors to run them. The contractor is responsible for employing the staff. I want BigOilCo. to supply my sites. No problem says BigOilCo, I see your credit is good, we will supply you. All good - my petrol stations are all branded BigOilCo. Six months later, OMG fire at one of my petrol stations, member of staff killed. Turns out he was an illegal immigrant, untrained, and had been working 16 hours a day in return for the share of a bunk bed and some basic food and £20 a week. Oh look, it's BigOilCo's name all over the papers. Then mine. Then the contractors.
Yes, if only lip service (as outlined above) is paid to the statement then it will still happen. However, if I'd taken a professional approach to my responsibilities I would have found out how my contractor was 'paying' his staff and potentially avoided the catastrophe.
That's why companies up and down supply chains should be taking it seriously.
Not really.Let's say I have 10 petrol stations. I don't want to direct manage them myself, so put in self-employed contractors to run them. The contractor is responsible for employing the staff. I want BigOilCo. to supply my sites. No problem says BigOilCo, I see your credit is good, we will supply you. All good - my petrol stations are all branded BigOilCo. Six months later, OMG fire at one of my petrol stations, member of staff killed. Turns out he was an illegal immigrant, untrained, and had been working 16 hours a day in return for the share of a bunk bed and some basic food and £20 a week. Oh look, it's BigOilCo's name all over the papers. Then mine. Then the contractors.
Yes, if only lip service (as outlined above) is paid to the statement then it will still happen. However, if I'd taken a professional approach to my responsibilities I would have found out how my contractor was 'paying' his staff and potentially avoided the catastrophe.
That's why companies up and down supply chains should be taking it seriously.
That's a HR and H&S failing.
HR should have checked his employment status and H&S should have risk assessed the site and done some basic competence training.
The domestic arrangements of your "employee" are not really the employers concern. Unless he is sleeping on the premises.
768 said:
Roman Rhodes said:
That's why companies up and down supply chains should be taking it seriously.
I can only see a story that illustrates that it's a crock of st.55palfers said:
Roman Rhodes said:
It isn't necessarily so pointless. Let me give a real world example with at least some relevance to PH - petrol stations:
Let's say I have 10 petrol stations. I don't want to direct manage them myself, so put in self-employed contractors to run them. The contractor is responsible for employing the staff. I want BigOilCo. to supply my sites. No problem says BigOilCo, I see your credit is good, we will supply you. All good - my petrol stations are all branded BigOilCo. Six months later, OMG fire at one of my petrol stations, member of staff killed. Turns out he was an illegal immigrant, untrained, and had been working 16 hours a day in return for the share of a bunk bed and some basic food and £20 a week. Oh look, it's BigOilCo's name all over the papers. Then mine. Then the contractors.
Yes, if only lip service (as outlined above) is paid to the statement then it will still happen. However, if I'd taken a professional approach to my responsibilities I would have found out how my contractor was 'paying' his staff and potentially avoided the catastrophe.
That's why companies up and down supply chains should be taking it seriously.
Not really.Let's say I have 10 petrol stations. I don't want to direct manage them myself, so put in self-employed contractors to run them. The contractor is responsible for employing the staff. I want BigOilCo. to supply my sites. No problem says BigOilCo, I see your credit is good, we will supply you. All good - my petrol stations are all branded BigOilCo. Six months later, OMG fire at one of my petrol stations, member of staff killed. Turns out he was an illegal immigrant, untrained, and had been working 16 hours a day in return for the share of a bunk bed and some basic food and £20 a week. Oh look, it's BigOilCo's name all over the papers. Then mine. Then the contractors.
Yes, if only lip service (as outlined above) is paid to the statement then it will still happen. However, if I'd taken a professional approach to my responsibilities I would have found out how my contractor was 'paying' his staff and potentially avoided the catastrophe.
That's why companies up and down supply chains should be taking it seriously.
That's a HR and H&S failing.
HR should have checked his employment status and H&S should have risk assessed the site and done some basic competence training.
The domestic arrangements of your "employee" are not really the employers concern. Unless he is sleeping on the premises.
The repercussions go far beyond the one man band. If the BigOilCo and I (in this example as owner of the 10 petrol stations) had taken our responsibilities under the Modern Slavery Act seriously rather than ignoring them or paying lip-service the catastrophe might have been avoided.
I see.
Existing H&S legislation places a statutory duty on the owner of the stations to ensure that when they hire sub-contractors to man the pumps as it were, they are in full compliance with H&S Regs as a minimum.
However, if an employer is knowingly employing illegals, no amount of legislation will make any difference. There is so little enforcement from all the agencies that dodgy employers know they are all but untouchable.
If local Councils employed more EHOs and fewer litter wardens....
Existing H&S legislation places a statutory duty on the owner of the stations to ensure that when they hire sub-contractors to man the pumps as it were, they are in full compliance with H&S Regs as a minimum.
However, if an employer is knowingly employing illegals, no amount of legislation will make any difference. There is so little enforcement from all the agencies that dodgy employers know they are all but untouchable.
If local Councils employed more EHOs and fewer litter wardens....
Edited by 55palfers on Wednesday 8th November 15:31
plasticpig said:
Got a client asking for our modern slavery statement. They weren't too happy when we told them we didn't have one as our turnover is considerably less than £36 million which is the point where a company is legally required to have one .
The woman we are talking to isn't our regular contact and is insisting we have to supply one and they can't do business with us without one. They aren't worth that much to us and I am thinking of asking them to raise a P/O to supply one. If they want a proper statement we have to chase down all our suppliers (around 40) and get their modern slavery statements (if they have one) . I suspect it could easily take a week just to gather all the statements together.
Anyone have any experience of this type of thing?
ask for theirs and then copy and past back to them.The woman we are talking to isn't our regular contact and is insisting we have to supply one and they can't do business with us without one. They aren't worth that much to us and I am thinking of asking them to raise a P/O to supply one. If they want a proper statement we have to chase down all our suppliers (around 40) and get their modern slavery statements (if they have one) . I suspect it could easily take a week just to gather all the statements together.
Anyone have any experience of this type of thing?
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