Our guidance on preparing a Modern Slavery Statement aims to support higher education and wider public sector organisations in developing human rights due diligence in their supply chain and reporting on what they are doing in their statements.
Statements should present the efforts, policies and processes undertaken by your institution, reflecting your journey towards fulfilling the responsibilities of the public sector towards those who provide the products and services we procure.
The Business, Human Rights and the Environment Research Group and LUPC have prepared this guidance based on our research and interactions with public buyers. We have kept it short and user-friendly, trying not to overload the reader and providing a quick ‘Dos and Don’ts’ list.
We hope you find the document useful, please do share it across your organisation.
Below, we have summarised some of the mandatory elements and general content of your statement:
Make sure your statement complies with the mandatory elements of the Modern Slavery Act, which are:
• To be visible in a prominent place on the website;
• Refer to work carried out in the previous financial year;
• Approved at the highest level of governance (Board of Directors or equivalent management body), include date of approval;
• Signed by someone at the most senior level (Director or equivalent).
• Report annually and about your past financial year, make it clear which financial year you are reporting on and keep your old statements online.
The content of your statement should refer to the following areas:
• The organisation’s structure, business and supply chains; provide relevant information that creates a picture of the structure of your business and your supply chains.
• Policies in relation to modern slavery and human trafficking; provide a link between your existing policies and modern slavery.
• Due diligence processes, risk assessment and management; identify high risks suppliers in your supply chains, this will help you to prioritise actions. Make sure you engage with suppliers and be clear about your expectations from them.
• Training on modern slavery and human trafficking; provide modern slavery training to all employees targeted in relation to each department e.g. human resources, procurement, legal, etc.
• Goals and Key Performance Indicators (KPIs) to measure the effectiveness of the organisation’s actions and progress over time; ensure you have KPIs related to modern slavery and track your short, medium and long term progress. Review goals and KPIs annually.