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What is Modern Slavery?
Modern slavery remains a violation of human rights and appears in a range of forms, all characterised by the exploitation of individuals and the removal of their autonomy, rights, and personal dignity. It occurs when people are coerced, manipulated, or deceived into labour, servitude, or trafficking situations where escape is restricted and freedom is denied.
Demand for inexpensive goods and services across global markets has contributed to environments in which such exploitation can thrive. Pressure from consumers, organisations, and public institutions to minimise costs can lead unethical operators to adopt harmful labour practices. In some cases, this results in modern slavery being embedded within business operations or extended supply chains.
Forms of Modern Slavery
Modern slavery manifests in a variety of ways, each involving the exploitation of individuals and the denial of their freedom. Common forms include:
Forced labour: Individuals are compelled to work involuntarily, often through intimidation, violence, or other forms of coercion
Child labour: Children are subjected to work that is exploitative, hazardous, or detrimental to their health, development, or wellbeing
Human trafficking: People are recruited, transported, or controlled through force or deception for the purpose of exploitation
Debt bondage: Individuals are trapped in work arrangements where labour is demanded to repay a debt, typically under unfair or abusive conditions that make repayment impossible
Forced marriage: A person is compelled to enter into marriage without freely given and informed consent.
Modern Slavery and Your Business
Understanding Your Business’s Exposure to Modern Slavery Risks
Modern slavery can occur in many different forms and may exist not only within a company’s direct operations but also throughout its broader supply chains. It is a common misconception that the risk only applies when a business is directly involved. In practice, gaps in governance, monitoring, or internal controls can allow exploitative practices to arise through suppliers, contractors, or other commercial partners.
Exploitation may involve tactics such as misleading recruitment processes, wage underpayment, substandard accommodation, or confiscation of personal identification documents. These practices can be connected to a business either directly or indirectly through its supply network. Because such risks can arise at any point in the supply chain, organisations with limited visibility or oversight are particularly exposed.
Limited awareness and understanding: Some organisations may lack sufficient knowledge to recognise the indicators or potential risks of modern slavery
Cost and operational complexity: Evaluating and managing modern slavery risks often requires significant time, expertise, and financial resources
Supplier engagement challenges: Working collaboratively with suppliers to identify and mitigate risks can be complex, particularly where expectations or capabilities differ
Complex, multi-tiered supply chains: The involvement of multiple layers of suppliers reduces visibility and makes risk identification and control more challenging
Varying legal and reporting obligations: Differences in regulatory frameworks across jurisdictions increase the difficulty of maintaining consistent compliance and reporting practices.
The Most Common Challenges Businesses Encounter with Modern Slavery Assessments
What Businesses Can Do to Prevent Modern Slavery
Every business, regardless of size or sector, has a role to play in identifying and preventing modern slavery. In response to growing global concern, governments in many countries have implemented laws that require organisations to assess, address, and publicly report on modern slavery risks. These measures are designed to improve transparency and accountability across supply chains.
By taking a proactive approach to identifying, managing, and disclosing these risks, businesses can gain greater visibility over their supply networks and help minimise the likelihood of exploitative practices occurring.
To effectively identify where modern slavery risks may exist, businesses must collect and analyse information about their suppliers. This involves assessing risk factors associated with geographic locations, industry sectors, and the types of goods or services being sourced. The risk factors should be examined in conjuction with how suppliers manage their workforce, policies, and labour standards.
This information should be reviewed on an ongoing basis, integrated into business decision-making processes, and shared with relevant internal stakeholders. Where applicable, it should also support compliance with modern slavery reporting and disclosure requirements within the relevant jurisdiction.
Essential Risk Data for Modern Slavery Assessments
The Most Effective Approach to Managing Modern Slavery Risks
The most effective response to modern slavery is a preventative one. Focusing on prevention allows businesses to reduce risk before harm occurs, rather than reacting after issues have been identified. This involves regularly reviewing supplier relationships and implementing clear policies, standards, and procedures designed to minimise the potential for exploitation.
By setting clear expectations within their own operations and with direct suppliers, businesses can also encourage those standards to be adopted further along the supply chain. This creates a stronger framework that helps protect against unethical practices emerging at any stage.
When evaluating modern slavery risks, an approach grounded in curiosity and collaboration is often the most productive. Seeking to understand on-the-ground realities and working cooperatively with suppliers to resolve issues typically delivers more sustainable outcomes than relying solely on a compliance-focused model.
Managing and Reducing Modern Slavery Risks in Your Business
Five Essential Capabilities for Managing Modern Slavery Risks
Supplier self-assessment: Systems and processes that enable suppliers to identify, assess, and disclose their own modern slavery risks
Reporting and analytics: Functionality to capture, review, and produce reports on risk information across the supply chain
Action planning and risk mitigation: Tools to develop targeted response plans, address identified issues, and monitor progress over time
Policies and preventative controls: Clearly defined standards and procedures designed to prevent modern slavery within business operations and supplier networks
Secure data management: Robust measures to ensure sensitive supplier and risk data is stored, managed, and protected appropriately.
Partnering with Suppliers to Address Shared Risks
Reducing modern slavery risks relies heavily on collaboration. When businesses engage constructively with their suppliers to identify and address risks, they are far more likely to achieve meaningful and long-term improvements. A cooperative approach encourages shared responsibility and practical problem-solving.
In contrast, the absence of collaboration can place strain on supplier relationships, shifting the focus toward enforcement and oversight rather than partnership. This can limit transparency and reduce the effectiveness of efforts to prevent exploitative practices.
Businesses should establish clear and well-defined modern slavery policies and actively use their influence to guide the practices of their direct suppliers. By embedding expectations into contractual arrangements and using flow-down clauses, these standards can be extended to Tier 2 suppliers and further along the supply chain. This provides the organisation control even where no direct commercial relationship exists.
Often, meaningful change begins with a single organisation setting clear expectations. From there, those standards can spread through the supply chain, creating a broader and more lasting impact.
Putting Modern Slavery Policies in Place
Assessing Suppliers Through Self-Assessment Questionnaires (SAQs)
Engaging directly with suppliers allows businesses to obtain first hand insight into modern slavery risks, along with the policies, procedures, and controls used to manage them. This approach improves the accuracy and clarity of reporting across both internal operations and extended supply chains, while reducing reliance on assumptions or secondary sources.
Access to supplier provided data also enables more targeted engagement at an individual level. Information gathered through supplier assessment questionnaires can be used to build detailed risk profiles for each supplier, while also supporting consolidated analysis that highlights broader trends and areas of concern across the supply network. When combined with a recognised and objective risk assessment framework, this data supports more practical, evidence based insights that can be translated into meaningful action.
Merely declaring that suppliers have been assessed is no longer enough. With increasing scrutiny from regulators, investors, and consumers, businesses are now expected to demonstrate the actions taken after assessments to address identified risks and prevent modern slavery on an ongoing basis.
Working collaboratively with suppliers supports continuous improvement and makes long-term risk reduction more realistic and effective. This approach helps move beyond box-ticking exercises and towards meaningful, sustained change across the supply chain.
Driving Continuous Improvement Through Action Plans
Using Onsite Audits as Part of a Risk-Based Approach
Onsite audits can play an important role in identifying modern slavery risks, but they are often costly and resource-intensive. A more practical starting point is to undertake a broad, high-level risk assessment across the supply base.
By working with suppliers to collect initial risk information from a wide group, businesses can develop an overall picture of where potential issues may lie. This approach allows organisations to prioritise and target onsite audits toward higher-risk suppliers, making more effective use of time and resources.
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