How To Deal With Modern Slavery

Dealing with modern slavery is a sequencing problem. Once a concern surfaces about a worker in your operations or a supplier’s, two separate decisions start running on two different clocks, and most organisations collapse them into one. The person’s immediate safety cannot wait and is largely not yours to control. The commercial decision about the supplier can wait, and usually should.

The instinct is to move fast and raise it with the supplier. That is the response most likely to cause harm. Warning a supplier gives them time to move people, alter records or dismiss the worker who spoke up, and it can expose that person to retaliation. Handling it internally as an investigation carries the same risk, because a business is not equipped to run one and has a commercial interest in the answer.

What tends to work in the first few days:

• Record what was actually observed or reported, in plain factual terms, and keep it tightly held.
• Route it through your incident management process rather than the commercial relationship, so it is logged and escalated instead of negotiated.
• Get specialist advice before contacting the supplier. Police involvement is one option among several and is not always what the person wants or needs.
• Say nothing publicly until the person is safe and has had a say in what happens next.

Remedy is where responses most often fall short. A corrective action plan signed by a supplier is not remedy if nothing changed for the worker. The Modern Slavery Response and Remedy Framework, published by Walk Free with the Human Rights Resource and Energy Collaborative and listed by the Attorney-General’s Department, sets out practical steps for responding to and remedying instances businesses find. Clear policy written before you need it beats improvising under pressure. This is general information rather than legal advice, and a suspected criminal matter warrants proper advice early.

Sentrient’s modern slavery course and the wider compliance training courses cover the awareness side of this.