A lack of resources or finance as the reason why modern slavery can’t be removed from a business’ operation is defunct. There is a moral obligation to humanity to ensure that nobody is subject to modern slavery conditions.
As small business’ transition and expand, how do they prevent and reduce operating in a manner that promotes modern slavery?
The current Australian Government, led by Prime Minister Malcolm Turnbull, has recently introduced a Modern Slavery Bill. This bill stipulates that businesses with an annual consolidated revenue exceeding $100m will be required to publish statements detailing processes and mechanisms in their supply chains and operations that address modern slavery. $100m is a substantial amount in annual consolidated revenue but it is only approximately 3000 businesses that will be compelled to publish statements. As of June 2017, there were more than 2.24 million active trading businesses in Australia. This leaves a significant percentage of businesses that aren’t directly compelled to take active action in preventing and reducing the influence that their business has on modern slavery. These businesses, smaller businesses, as they strive to grow and expand in to a market can still ensure that the manner in which they operate doesn’t endorse, enhance or promote modern slavery.
What can small businesses do?
Recording the organisation’s structure with businesses and supply chains.
This will set up a platform to identify if there is any existing and/or future modern slavery within a small business’ functions. As a small business becomes bigger, mapping must be enhanced and expanded as it is imperative any new suppliers are not engaging in any form of modern slavery. Important that your product is not going to a business that promotes modern slavery.
Developing policies on modern slavery – this will involve collating current policies, identifying gaps, adapting existing policies and designing new policies, as needed.
It is important for a small business to know where it sits and where it wants to go. If it has a goal of complete absence of modern slavery then this will need to be reflected in its policies; current and future. Understandably, if modern slavery has been identified in a particular supply chain, it may take time to eradicate this. However, if policies reflect future goals then the small business can raise awareness as it moves towards eliminating the presence of modern slavery within its systems.
Carrying out a risk assessment – identifying those parts of the business operations and supply chains where there is a risk of modern slavery taking place.
Identification of an issue is the first step. Supply chains are a good example of where a risk assessment can be carried out. Questions that can be asked are:
- Where is the material, products or services coming from?
- International or local location?
- What are the modern slavery policies of the businesses providing the material, products or services?
- What are the modern slavery policies of the businesses reflective of?
Assessing and managing identified risks – this may include carrying out further due diligence in the entity’s operations and supply chains and reviewing and adapting contract terms and codes of conduct with suppliers.
It’s been identified that there is modern slavery present, in one form or another, and it isn’t reflective how a small business wishes to operate. Start making enquiries where modern slavery has been identified. Is there a simple solution that can benefit all parties? It may be that a particular supply chain needs to be completely removed due to a strong modern slavery presence. Other times it may be that policies, systems of work or contracts can be updated and altered to reduced and eliminate its occurrence. If a supply chain has to be completely cut off, it may be that relevant authorities need to be notified.
Considering and establishing processes and KPIs to monitor the effectiveness of the steps taken to ensure that modern slavery is not taking place in the business or supply chains.
Creating policies that have no effect is waste of time. KPI’s enable effect to be measured. If there hasn’t been a reduction, then it may be that small business polices, supply chains or the business structure needs to be changed. Establishing regular meetings to discuss modern slavery is a platform that can be easily established.
Carrying out remedial steps where modern slavery is identified including highlighting the operations of the offending business and changing suppliers if necessary.
As aforementioned, where there is presence modern slavery, the process should be to reduce and eliminate. Establish that there is an issue and decide on an appropriate course of action. Changing suppliers, altering business structure and alerting authorities are a few options available to a small business. Updating the businesses policy on modern slavery as it expands is important because it can be identified and avoided before remedial steps need to be employed.
Develop training for staff on modern slavery identification, risks and impacts.
Small businesses can start with awareness; the greater the knowledge, the easier it is identified and subsequently the easier it is reduced and eliminated. Ensure staff are aware of policies and the businesses position on them. Information sessions are the perfect place to start.
A lack of resources or finance as the reason why modern slavery can’t be removed from a business’ operation is defunct. There is a moral obligation to humanity to ensure that nobody is subject to modern slavery conditions. It is also an obligation, not only to reduce and eliminate, but to influence this position on everyone.