Impact 101: Human Rights & Modern Slavery
The world of social and environmental impact can be complex. At Impactful we want to break down some of that complexity and help you understand areas where you can mitigate, manage and improve your impact. Over the coming months, we’ll be taking a look at different areas of your business and give you the information and tools you need to take action.
First up, we’ve partnered with Harriet Von Spiegel from RightsDD to explore how you can prevent human rights abuse and modern slavery in your supply chain & business operations. Let us know if you found this useful & if there are any other topics you’d like us to explore. Sign up to get these in your inbox here.
In July 2020 allegations emerged that workers supplying the fashion brand Boohoo were working in conditions tantamount to modern slavery in Leicester. The workers were being paid as little as £3.50 per hour, well below the UK minimum wage of £8.72.
Modern slavery is an umbrella term used to describe severe human rights abuses including human trafficking, forced labour, the worst forms of child labour and debt bondage. According to the International Labour Organisation (ILO), today approximately 16 million victims of modern slavery are being exploited in business supply chains to produce the goods and services we consume. The Walk Free Foundation estimates that at least 136,000 people were subject to modern slavery in the UK in 2018. In 2018 alone the value of goods imported into the UK and at-risk of being produced by forced labour was estimated at £18 billion.
How might small businesses cause or contribute to Modern Slavery?
Contrary to common belief, modern slavery takes place in every country and industry. However, certain factors greatly increase the risk of workers being exposed to slave-like working conditions.
The use of recruitment agencies to hire laborers is, for example, a common practice among small businesses. However, some recruitment agencies engage in illegal practices by charging workers recruitment fees* or excessive travel expenses**. To secure their employment, workers may go into debt; leaving them in a highly vulnerable and dependent position which can eventually result in debt bondage. While outsourcing the recruitment of workers is a common practice, companies cannot outsource their responsibility to ensure that their workforce is recruited in a fair and ethical manner.
What are companies expected to do?
In 2011, the UN Human Rights Council adopted the UN Guiding Principles on Business and Human Rights (UNGPs), a global standard confirming the responsibility of all enterprises, regardless of size, to respect human rights and prevent or mitigate abuses in their operations and supply chains. The UNGPs introduced the concept of human rights due diligence, a continuous process to identify, address and remediate adverse human rights impacts.
Drawing on the UNGPs, several countries — including the UK, Australia and the Netherlands — have adopted new supply chain laws which specifically address modern slavery. Section 54 of The UK Modern Slavery Act (2015), for example, requires certain companies to publish an annual Modern Slavery Statement outlining the steps they have taken to mitigate modern slavery risks.
Many smaller businesses fall below the revenue thresholds mandated in the laws and are therefore not directly subject to the respective laws. Small businesses might however be indirectly affected when supplying to larger companies which are subject to the reporting obligations. Larger clients may require their suppliers to provide information on their business activities and risk mitigation mechanisms. Aside from legal compliance, consumers, investors and employees also increasingly expect companies to conduct business in an ethical manner. To mitigate reputational risks companies are best advised to engage in modern slavery due diligence.
How can you tackle modern slavery in your business supply chains?
Modern Slavery is a systemic issue requiring a holistic approach. As a small business leader you might face challenges through lack of resources, capacities, and leverage over larger suppliers. The implementation of a comprehensive modern slavery due diligence process is critical to meet these challenges. Modern slavery due diligence refers to the identification of actual and potential slavery risks, the implementation of adequate mitigation mechanisms, monitoring the effectiveness of the adopted measures and public disclosure of the due diligence process. Mitigation measures are dependent on your company’s risks and can range from simple awareness rising practices such as modern slavery training to the adoption of new supplier policies or the implementation of factory audits.
About RightsDD
RightsDD is a London based startup offering smart technology solutions to help your company conduct modern slavery due diligence. We offer a variety of products and services including:
RightsDDnow, a free slavery risk assessment tool, provides you with an overview of high-risk areas in your company’s own operations.
RightsDDpremium, a solution for assessing supply chains for slavery risk and identifying and managing high risk areas.
Additional Resources
- RightsDD resources page
- UN Guiding Principles on Business and Human Rights
- OECD Guidelines for Multinational Enterprises
- Walk Free Foundation Business Toolkit
- Why your CSR policy is not enough to tackle Modern Slavery
- Tackling Modern Slavery in Supply Chains — A Guide
We hope you found this guide useful. Contact RightsDD to learn more about how human rights and modern slavery might impact your business. You’ll find more resources from us at Impactful on our website & you can follow us on Twitter too.
*Agencies are banned, except in certain circumstances, from charging workers recruitment fees. See https://www.gov.uk/agency-workers-your-rights/fees.
**Agencies must ensure that any deductions for travel expenses do not reduce workers’ pay below the minimum wage. See: https://www.citizensadvice.org.uk/work/rights-at-work/agency-workers/can-your-agency-charge-you-fees/
