Human rights risks in supply chains can be complex and may occur beyond the immediate visibility of organisations. Nonetheless, investors and other stakeholders have increasingly turned their attention to how organisations are managing and mitigating these risks, especially in the context of the Commonwealth Modern Slavery Act 2018.
A starting point for managing and mitigating modern slavery risks is conducting a supply chain risk assessment for the client. Although Australia’s estimated prevalence of modern slavery or poor labour rights is relatively low, there may be pockets of risk within domestic supply chains that require attention (e.g., labour hire, commercial cleaning, etc.). That said, we typically help clients turn their attention to their offshore value chain, with particular focus drawn to jurisdictions where modern slavery and labour rights abuse remain higher risk.
A key consideration for the managing and mitigation of these risks is whether an appropriate policy framework to govern the organisation’s approach is in place. Guerdon Associates supports clients in developing and reviewing a relevant suite of policies (e.g., responsible procurement policy, supplier code of conduct, human rights policy, etc.) with the view that the policy framework clearly lays out responsibilities and accountabilities and can be implemented effectively.
Given the key role suppliers play in managing modern slavery risk, we work with clients to design and review contractual controls to place reasonable conditions on suppliers’ relationships with the client. To support these contractual controls, we design supplier due diligence frameworks so that clients can conduct ongoing monitoring of supplier compliance with expectations. We also work with clients who want to align their approach with international standards and guidance such as ISO 20400, Sustainable procurement – Guidelines.
Australian organisations may be required to meet the statutory reporting obligations of the Modern Slavery Act 2018. When we draft and review Modern Slavery Statements, our focus is not just on black letter compliance, but also on how to meet the disclosure expectations of investors and other key stakeholders.