The 18th of October marked Anti-Slavery Day, providing the opportunity to raise awareness of modern slavery and to encourage government, local authorities, charities, individuals and companies to address the problem.
Since the implementation of the UK Modern Slavery Act (MSA) in 2015, organisations meeting the legislation threshold are required to produce an annual statement setting out the steps taken to combat the risk of modern slavery in their organisation and supply chains.
We have been working with Olympia London to help implement the objectives set out in their previous modern slavery statement. The business has a strong approach to corporate responsibility and in complying with the MSA it wanted to secure best practice, reaching far beyond the spectrum of business reputation, compliance and accountability. It forms part of their approach to ensuring that sustainability is at the core of how the venue conducts its business and through its in-house programme, the Grand Plan.
Working with Ardea International they have integrated the risk of modern slavery across their procurement function. The steps taken to tackle the risk of modern slavery were:
1. Updating all its policies, including its procurement and supply chain policies to include specific references to modern slavery. This involved a gap analysis of all the documents and updating them with suitable wording.
2. Developing a risk assessment tool and supplier questionnaire to identify and better understand where the greatest risk of modern slavery may occur in their supply chain. The supplier questionnaire was sent to those suppliers identified as high risk and the responses will be monitored, and acted on if necessary.
3. Reviewing its terms and conditions and updating contract templates. The updated templates were sent to all key suppliers.
4. Updating the invitation to tender document to include specific references to the consideration of modern slavery.
5. Provided training to procurement managers and staff in recognising modern slavery risk and following the new policies and procedures put in place. The training involved a masterclass session with all the key managers to understand how modern slavery risk could impact on the business and their roles. Uniquely we also provided a lecture for all the staff with an opportunity for questions and answers. Once the procurement framework was updated, including all the policies and supporting documents, we carried out a further training course with key employees so that they were able to understand the changes that had been made and how to manage their own procurement functions going forward. A refresher masterclass is set for next year.
This work has identified further actions needed in 2019 to continue to develop the steps within the organisation to effectively tackle modern slavery. An updated statement has been uploaded on the website, alongside the previous statement to demonstrate improvement.
☛ Colleen Theron is director at Ardea International.