Guide to modern slavery in supply chains training
Modern slavery presents a risk to your company and the people working for it. To help tackle it, your employees need to be trained. However, you may know little about the subject. A poor programme may do more harm than good.
In this guide we explain why you should conduct modern slavery training, what it is, how to deliver it, what needs to be included in it, who should be trained, and when it should be delivered.
Disclaimer: nothing in this guide is to be construed as legal advice. This guide is for informational purposes only.
Why implement a modern slavery training programme?
There are 17 million victims of modern slavery being exploited in global supply chains today. To prevent this abuse, companies need to act. Not only is it the right thing to do, but it can help protect your company from risk and ensure compliance with an expanding array of new laws.
Slavery is an abuse of internationally recognised human rights and a crime in nearly all jurisdictions. It is therefore critical to ensure that it is not occurring in your own operations. It’s also important to take steps to help prevent it in your supply chains.
Failure to tackle slavery may damage the company’s brand and cause operational problems. In may even hit your share price, for example Boohoo’s stock fell 50% after accusations
of labour abuse in its supply chain.
Companies are required to report on the steps they are taking to tackle slavery, including training, by laws such as the Australian and UK Modern Slavery Acts. Canada and the United States bans the import of goods made by forced labour (a form of slavery) and any company importing to these countries needs to ensure compliance.
For these reasons, your colleagues need to be able to identify, and appropriately react to, the warning signs of modern slavery. They therefore need to be trained. While modern slavery training is not compulsory under the Australian and UK Modern Slavery Acts, it is encouraged to conduct it and report on it in modern slavery statements.
What is modern slavery training and how should you deliver it?
Modern slavery training is a way for companies to lower slavery risk in their operations and supply chains. It should be tailored to your industry and company, as this will help employees spot potential instances of slavery. It should also familiarise them with your company's anti-slavery policies. Training can be delivered via the following mediums:
- Online training course. Cost-efficient way to train large numbers of employees in multiple languages. Many companies already have a learning management system (LMS) through which the course can be distributed. Well-designed courses can be engaging and tailored to your company. Easy to incorporate in-course testing.
- In-person. Most interactive and allows for questions and answers. Best suited for specialist roles and/ or senior leadership. Typically, can only be delivered to small groups and it is therefore costly to deliver to large workforces, it can also be hard to schedule in-person training.
- Webinar. Allows for questions and answers. Can be delivered to larger groups, though this comes at the cost of interaction.
What needs to be included?
Content needs to be relevant, engaging, accurate, and informative.
While modern slavery is a clearly defined group of criminal acts, it manifests itself in very different ways in different industries. Even within a given industry, two companies may have different risk profiles (often dictated by the geographies in which they operate) and different risk mitigation measures (e.g. how whistleblowing/ speak up is managed).
At a minimum, your training should be tailored to your industry, and ideally to your company. This will best equip your colleagues to tackle slavery and drive engagement.
There is little point delivering training if those receiving it don’t learn from it! Training therefore needs to be engaging. Ensuring your training is relevant (see above) is key here, as people engage with content that they can easily relate to. We have also found that using a variety of media (including videos, written content and quizzes) drives engagement.
People relate best to people, so consider integrating victims’ stories. See ‘Victim stories’ below for more on this.
Modern slavery is a complex issue. Your course needs to be accurate. Getting it wrong can be damaging. While it is critical to get the human rights side of the training correct, its also important to ensure that the course focuses on risk in business operations and supply chains.
Given the above, your training should be created or reviewed by a human rights expert with business experience. If you are using a general provider of corporate training content, we strongly recommend that you check the credentials of the course creator. Unfortunately, we have come across training courses that contain inaccurate or misleading information.
Your syllabus should be tailored to your company and audience. We would expect however, that the following topics are included in the course:
Start with a message from your company to the participants explaining why tackling slavery is important. Your company has likely adopted an anti-slavery position, which will be located at the start of your modern slavery statement. Consider including this in the introduction to the course.
Give participants the key, and shocking, facts about the scale of modern slavery in business supply chains. Finally, provide an overview of the curriculum.
Consider including an explanation of why it is commercially beneficial for your company to tackle slavery. It is of course important to strike the right balance here and ensure that the human side of the issue remains the focus.
What is modern slavery?
Define what modern slavery is. Include an explanation of the different forms of modern slavery (slavery, servitude and forced or compulsory labour, and human trafficking).
Provide an overview of the laws that prohibit slavery and the regulations that your company has to comply with. Tailor this to your audience. For example, if your company does business in Germany certain functions (e.g. legal, compliance and procurement) may benefit from a full overview of the new German supply chain due diligence law
. Don’t swamp your audience, however. Most employees at most companies only need a brief overview of the legal landscape.
How does slavery manifest in businesses?
Provide an overview of risk that may be present in your own operations and in your supply chain. The risk profile can vary considerably by company. For example, slavery risk at a technology company may be concentrated at the second or third tier of a supply chain, where components are manufactured. Whereas, in healthcare the people most at risk could be temporary workers placed into the business by agencies.
How to spot the warning signs
Use the International Labour Organization’s Indicators of Forced Labour
as the basis for this section. They are highly authoritative and are used by the likes of the US Customs and Border Protection agency
to determine whether to detain imports to the United States on forced labour grounds.
You can examine each of the indicators separately or use case studies to explore them.
Telling victims’ stories can help build empathy, which in-turn makes people care more about the topic. If you chose to include victims’ stories, it is of course important to ensure that their stories have been willingly shared and any privacy concerns are addressed.
How your company addresses it
Explain how your company manages modern slavery risk. This will likely include due diligence of suppliers (see our guide to modern slavery due diligence for more information), a speak-up facility and policies.
It is particularly important that any relevant obligations and responsibilities are explained. For example, many companies require their employees to follow strict incident management procedures when reporting any suspected incidences of modern slavery.
If you are a learning and development manager, or another member of the human resources department, it is advisable to liaise with other departments (including procurement, sustainability and legal) to confirm what processes the company has in place.
Interactive content is more engaging than passively consumed content. We therefore recommend integrating quiz content throughout, or at least at the end of the course.
If the training is in-person you can do this via questions and answers and/ or set a paper quiz. If you opt for an online training course you should be able to set quizzes in your Learning Management System. For clients that have their own LMS we typically deliver our courses in the SCORM file format (which accommodates quizzes). For clients that don’t have their own LMS we provide access to their employees via our own technology.
Set a mandatory score threshold If you wish to measure employees’ understanding of the topic.