Anti-Slavery and Human Trafficking Policy

Modern slavery is a crime and a violation of fundamental human rights. It can occur in a number of forms such as:

• Slavery: exercising powers of ownership over a person
• Servitude: the obligation to provide services is imposed by the use of coercion
• Forced or Compulsory Labor: work or services are extracted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
• Human Trafficking: arranging or facilitating the travel of another person with a view to their exploitation

All of which in common deprive a person’s liberty by another to exploit them for a personal or commercial gain.

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A company can help prevent and abolish anti-slavery and human trafficking internally and from its own suppliers and business partners by adopting an anti-slavery and human trafficking policy which is aligned with the principles of the Modern Slavery Act 2015. By adopting an anti-slavery and human trafficking policy, a company will expect the same high standards from its contractors, suppliers, their own suppliers and other business associates.

What are the key terms of an anti-slavery and human trafficking policy?

The company prohibits the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. The main terms of the policy are:

• Policy responsibility: who is responsible for ensuring the Company complies with the policy and who has primary and day-to-day responsibility for implementing and enforcing effective systems for tackling modern slavery throughout the Company?
• Compliance with the policy: how must workers comply with the policy and how does the Company encourage openness and provide support to Workers who wish to raise concerns?
• Communication and awareness of the policy: how are Workers, suppliers, external consultants and other business partners made aware of this policy?
• Breaches of the policy: how will the Company deal with breaches of the policy and what will happen to employees, individuals or organisations if they are in breach of the policy?
• Identifying modern slavery: how can employees identify key signs of modern slavery, human trafficking or forced labour?
• Policy review: how is feedback on the policy processed and how will the policy be updated to ensure it meets legal and ethical obligations and that it reflects best practice?

Who is responsible for implementing a company's anti-slavery and human trafficking policy?

The Chair of the Board has overall responsibility for ensuring the company complies with this policy and a senior member of management such as the Chief Executive or a Managing Director  has primary and day to day responsibility for implementing the policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

How to create an anti-slavery and human trafficking policy?

As a company matures, it will be expected to hold itself and its business partners accountable to ensure that it is committed to acting ethically and that its business dealings and relationships are not encouraging or benefiting from forced and compulsory labour or other forms for modern slavery. Larger organisations will often request copies of a company's modern slavery policies during the contracting processes before starting a business relationship. Creating a policy at the earliest possible stage of a company helps reduce the likelihood of modern slavery occurring in its business or supply chains whilst minimising friction when contracting with larger organisations. Companies using Legislate can create a broad range of policies tailored to their own business requirements and can demonstrate that their employees and collaborators have read these policies thanks to e-signatures within Legislate. To create policies, simply book a demo or create an account to get started today.

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