Behind the standard: Eradicating modern slavery Part 2: Risk mitigation and management
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February 9, 2023 - BS 25700 provides guidance for organizations on managing modern slavery risks within their operations and supply chains. In part one of “Behind the standard: Eradicating modern slavery,” we examined the risk factors in modern slavery for organizations to identify. Now, in part two, let’s take a look at how organizations can mitigate and manage those risks.
Developing a modern slavery policy
To mitigate the risks of modern slavery, the standard recognizes that a policy and statement must be put in place by leadership. The organization’s values, principles, and reporting structure should be formally agreed upon by top management and reflect a strong commitment to identifying and addressing unethical behavior. The management of the policy can then be integrated into all business activities. The standard recommends that the modern slavery policy:
- Identify any authorities and delegations required, including the person(s) responsible for the organization’s policy.
- Include references to standards, guidelines, regulations, or policies to be considered or complied with.
- Reassess at planned intervals and communicate with relevant stakeholders.
- Include a funding commitment and references to other related policies.
- Be accessible for public viewing and tailored to different audiences so anyone who reads it can understand it.
It’s imperative that the policy is communicated internally and externally in a meaningful, timely, and consistent way. Communication should include a feedback mechanism and a review cycle, incorporating provisions to proactively address changes in the organization's environment.
Managing the risk of modern slavery
Managing the potential risk of modern slavery is critical to prevent harm to workers and protect the reputation of an organization. The implementation of a risk assessment is recommended to manage potential risks. Elements of the risk assessment can include but are not limited to:
- Engaging with suppliers on a continual basis to prevent, mitigate, and remediate the risk of modern slavery. If a supplier presents an intolerable risk, the organization should terminate the business relationship and seek an alternative supplier, but only after efforts have been made to support supplier improvement on the issue.
- Providing clear policies and processes to address these risks. Policies should be assessed periodically or whenever there are changes in organizational circumstances.
- Identifying, analyzing, and evaluating the exposure to risk in relation to the organization’s activities, products, services, and relevant aspects of its operations, including outsourced third-party and wider value-chain processes.
- Following steps that allow those affected by modern slavery risks to confidently voice their concerns and access effective remedies without being penalized. The business should be victim- and worker-centric to allow sufficient identification and prevention of risks.
- Updating due diligence at a defined frequency and fully documenting, including sources, so that any potential or actual modern slavery risks can be properly considered, and an appropriate action can be taken to manage that risk.
Resources on risk management should be readily available to stakeholders, and reporting should be transparent. Top management should determine the competencies needed for modern slavery management roles, and all persons assigned a role within the organization should be provided training to enable them to demonstrate these.
Follow along with Ryan Lynch’s three-part series “Behind the standard: Eradicating modern slavery” to learn more about BS 25700: Organizational responses to modern slavery and listen to BSI’s latest episode of The Standards Show, Eradicating modern slavery. To learn how to build an organizational ESG plan, check out Ryan Lynch's Tackling Decarbonization series installment on ESG Planning Strategies. Visit BSI's Experts Corner to read more on this topic in the series Fundamental of human rights and other important human rights issues including Sustainable supply chains.
