Modern Slavery Act 2015 – have you been asked to respond?
More distributors are being asked to ensure that their supply chain adheres to the Modern Slavery Act, as big brands and many leading charities look to ensure that their strong ethical values are adhered to. Here is what one distributor was asked recently?
XX has clients who will not work with any supplier that either uses, or does not have the necessary controls in place to prevent the use of modern slavery or human trafficking in their own business or their supply chain.
Under the Modern Slavery Act 2015 our clients have a responsibility to make a clear statement of what they are doing to ensure that their business and supply chains are free of modern slavery and human trafficking.
Please provide answers to the following questions to enable us to ascertain how you are managing your responsibilities under the Modern Slavery Act 2015, and if applicable, a copy of the statement that you are required to provide under the Act.
1. Do you have or are you in the process of creating either a Modern Slavery Act or ethical policy that covers not only your own operations but those of your contractors and sub-contractors? If so, please provide a copy.
2. Do you have governance procedures in place to ensure compliance to your policy? If so, please provide copies.
3. Do you source or manufacture your goods/services outside of the UK? If so, please detail where and what part of your supply chain takes place in those countries, i.e. manufacturing, warehousing etc.
4. When sourcing goods/services, what due diligence do you undertake to ascertain that your sub-contractors are not using any form of slavery or human trafficking either directly or in its supply chain?
5. Do you undertake regular audits of your supply chain to ensure that suppliers are not using slavery or human trafficking to resource their workforce? If so, please provide details of the type of audit you undertake and whether this differs depending on the perceived risk.
6. Do you have contractual obligations in your contracts with your suppliers to guard against modern slavery in your supply chain? Have you ever terminated a contract because modern slavery or human trafficking has been found in your supply chain?
7. What human resource processes do you have in place to ensure that you do not employ staff directly that could be considered under the Modern Slavery Act as slaves or as human trafficked?
8. If applicable, please provide your Modern Slavery Act statement that you have or will be publishing on your website and with your annual financial accounts.
So how do distributors with a widening supply chain, meet these requirements. Have you experienced similar requests from clients? Product Media would like to hear from you. Send your thoughts to Gordon@bpma.co.uk