Take Action on Trafficking and Forced Labour

In partnership with Finance Against Trafficking (FAT) and ECCR corporate members – Us (formerly USPG) and Rathbone Greenbank – ECCR recently released the report ‘Forced Labour, Human Trafficking & The FTSE 100’.

As the Modern Slavery Act 2015 comes into force, companies face unprecedented scrutiny in ensuring their supply chains are free from forced labour and human trafficking. New guidance, within the report gives faith investors the knowledge to challenge companies and ensure they are working to the highest standards in this area and in so doing, help protect some of the world’s most vulnerable people.

The questions below are questions that faith investors can ask in order to hold companies to account in this area.

Suggested Questions for Companies
The following questions can be directed at companies by shareholders, pension fund investors or investment managers:

  • What steps are you taking to ensure compliance with the Modern Slavery Act?
  • What actions have you taken to evaluate and address the risks of forced labour, slavery, human trafficking, and child labour within your product supply chains?
  • What policies have you put in place to identify and elimi-nate risks of forced labour, slavery, human trafficking, and child labour within your supply chains, and what actions have you taken in relation to, or in the absence of, such policies?
  • How will you ensure that audits of suppliers within your supply chains are conducted to investigate working condi-tions and labour practices and to verify whether suppliers have systems in place to identify risks of forced labour, slavery, human trafficking and child labour within their own supply chains?
  • How will you manage your suppliers to ensure that the manufacture of products and the recruitment of labour is carried out in compliance with applicable legislation re-garding forced labour, slavery, human trafficking, and child labour?
  • What steps have you taken to establish and maintain internal accountability standards and procedures for employees or contractors that fail to meet company standards regarding forced labour, slavery, human trafficking, and child labour?
  • What training have you provided to your employees and personnel with direct responsibility for supply chain management regarding forced labour, slavery, human traffick-ing, and child labour?
  • How will you ensure that labour recruitment practices comply with corporate policies and/or efforts to eliminate practices that contribute to forced labour, slavery, human trafficking, and child labour?
  • How will you ensure that remediation is provided to those who have been identified as victims of forced labour, slavery, human trafficking, and the worst forms of child labour within your supply chains?

Suggested Questions for Fund Managers and Pension Fund Trustees
If your investments are held by investment managers or pension funds, you can ask the following questions to ascer-tain the extent to which they are raising concerns about forced labour, slavery, human trafficking, and the worst forms of child labour with the companies in which they in-vest your money. This will encourage them to do more in this respect.

  • What are you doing to ensure that the company in which you are investing on my behalf is taking adequate measures to ensure that forced labour, slavery, human trafficking and child labour are not present within its supply chain?
  • With how many companies have you raised concerns or asked questions about the risk of forced labour, slavery, human trafficking, and child labour either within their own operations and/or those of their suppliers?
  • In what ways have you engaged with companies on the issue of modern slavery?
  • How will you be monitoring companies’ compliance with the Modern Slavery Act?
  • In what ways have you engaged with national and interna-tional policy makers on business and human rights agendas?
  • What industries and asset classes do you consider to be higher risk for the incidence of modern slavery?