To prepare for reporting requirements under the Modern Slavery Act, organisations should ensure that they have in place a suitable Supplier’s Code of Conduct.
Generally speaking, a company’s Code should address:
Organisations affected by the legislation should engage subject matter experts to not only assist in the preparation of a legally appropriate and company-specific Modern Slavery Code of Conduct, but also to conduct multi-faceted inspections and audits on their actual supply chains.
This is to ensure that the standards stipulated in the Code of Conduct are actually being implemented and upheld. Organisations should also prepare and implement effective remediation and rectification procedures to provide, where appropriate, support and guidance to their suppliers for the adequate resolution of any breaches.
These practical steps represent a useful starting point for Modern Slavery Act compliance. However, beyond compliance organisations need to be cognisant of the marketplace opportunity for optimal human rights protections to be achieved through the voluntary imposition of commercial contractual obligations.
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