The Modern Slavery Act: putting theory into practise

We’ve been helping many organisations prepare and implement a structured response to the Modern Slavery Act. Nicole Thompson, Edge’s Head of Sustainable and Ethical Procurement, recently sat down for a chat with those leading the response to modern slavery in the building and construction sector – Pat Trotter (FDC Construction & Fitout), Mark Tonkin (Buildcorp) and David Sharp (Richard Crookes Constructions). While discussing the challenges they all face as part of the supply chain, they shared with Nicole their experiences, insights and advice for the future.

Pat, David and Mark, who in your organisation has been involved in responding to the Modern Slavery Act?

Pat: We appointed a specific team to coordinate all our efforts, with sub-groups to represent each division. Each group is actively involved in different facets of our modern slavery response.

David: We also established a specific working group. Currently it’s our CFO, Head of Commercial and Risk, Business Systems Manager and Sustainability Manager but it will expand out to include others from across the business.

Mark: We created a dedicated Modern Slavery Working Group (MSWG) to develop and manage our program roll-out across the company.

What have you found to be the biggest challenges to understanding and addressing the modern slavery risk?

David: Our focus has been on improving our own education and awareness, as well as ensuring we understand our obligations as part of the supply chain. It really requires educating the whole of the business because only then can you keep the momentum and get it ingrained in BAU.

Mark: We found a lack of interest challenging from some sub-contractors, particularly if a problem existed beyond their local operations. Construction product supply chains are often very long, complex and opaque, with many small and family-run businesses lacking the resources to undertake the due diligence needed. And if they are not legally required to comply, there is no pressure to address the issue.

Pat: We also found that although general awareness of modern slavery risk was fairly high, educating our staff and suppliers about the less obvious risks is going to be an ongoing challenge.

Based on your experience assessing and managing modern slavery risk, how ready is your supply chain to respond to the Modern Slavery Act?

Mark: Because we immediately appointed a working group, we were able to quickly develop a digital training module and awareness program. We also have on-site awareness posters that target our sub-contractor network as part of our ongoing efforts to assess and improve risk. All this enables us to continually improve our ability to assess risk.

Pat: We have found that the larger suppliers are more familiar with the Modern Slavery Act and familiar with the requirements and prepared to commit the resources to respond appropriately. Smaller suppliers may well be supportive, but they often lack resources and are still in the process of determining the most effective action.

What can your suppliers or contractors do to help you achieve supply chain transparency?

David: Honesty and collaboration are the most important things. We need help and transparency in understanding the downstream processes and risks, and, equally, we can help them with education and awareness.

Pat: Supplier honesty and integrity is all we ask at this stage – anything that can help improve our understanding and collective knowledge of issues and risks. We are very conscious of keeping the process constructive rather than accusatory.

Mark: We ask that suppliers and contractors be aligned with our policies and share information that may once have been considered confidential. It’s only if we are equipped with the appropriate knowledge and resources that we can drive a culture of change and challenge old thinking. Transparent discussions within a supply chain need to be the new norm.

Over the last 18 months, what factors have enabled the successful implementation of mitigation actions?

Pat: The acknowledgement and acceptance from our workforce and suppliers that some form of human rights abuse exists in all supply chains has made it much easier to implement our initiatives.

David: Although we’re still very much in the education and awareness phase, creating an overall action plan that breaks modern slavery down into key target areas (education and awareness, due diligence and monitoring, process improvement, etc) allowed us to set realistic goals, monitor progress and continue to develop and improve.

Mark: It’s also very early days for us. Buildcorp began its modern slavery risk management program one year ago with a focus on preparing the business to support our mitigation strategy. Supplier modern slavery due diligence will be our next step.

What is one key action or focal point that your organisation will take in the next 12 months?

Mark: Our mitigation strategy is the next step. We will start with education and awareness among staff, subcontractors and suppliers. Focussing on high-risk areas, we’ll then implement due diligence processes, which will ultimately cover all aspects of our modern slavery risk framework.

Pat: Increased awareness is an ongoing focus, particularly around foreign and vulnerable members of our workforce that come on site.

David: We will continue to identify and focus further on some of the high-risk procurement categories as well as working with partners to gain a better understanding of the supply chain – and the actions they’re taking to assess and address modern slavery risks.

What advice can you give to those organisations starting out?

Pat: Lead by example. The better example your own organisation can set, the easier it is to engage with others. This is the only way to improve transparency and achieve better industry practices.

David: I would say be realistic about what you can achieve. It’s all about continuous improvement, so only focus on a couple of items at a time.

Mark: My advice would be to create a dedicated working group and take a progressive approach towards implementing modern slavery strategies. The concept of modern slavery will be new to many organisations and employees, and a progressive rollout enables you to adjust initiatives as required.

Thank you to Pat, David and Mark for taking the time to share their experiences in their first year reporting under the Modern Slavery Act.

To find out more on how to assess your modern slavery risk, get in touch with Nicole Thompson, our head of Sustainable and Ethical Procurement.

Nicole Thompson
Nicole Thompson

Head of Sustainable & Ethical Procurement | Principal Consultant


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