Regulation is now saying: it is no longer enough to allow the complexity of global supply chains to prevent you from uncovering Modern Slavery. So how should your business respond?
This week in Davos the World Economic Forum is asking itself – what are the most effective levers to put an end to modern slavery? A nuanced, multi-layered response is required, explains Dr Meg Brodie, Human Rights Service Line Lead
KPMG Banarra Human Rights & Social Impact Services.
There is no single lever to create change – the pernicious practices which subject over 40 million people worldwide to slavery-like conditions cannot be ended by compliance, civil society campaign or regulatory reform. Right now, in jurisdictions where business is being asked to do more to address modern slavery and other human rights impacts, it is fair to say that there is deep concern and fear at the top of corporate governance structures: how can we possibly understand, identify and respond to hidden violations across our all operations and throughout our whole supply chain?
Nevertheless, the sphere of influence business exercises is considerable, and it is here that business can choose to pull certain levers. Regulation is now saying: it is no longer enough to allow the complexity of global supply chains to prevent you from uncovering your impacts. So how should business respond? In this blog, we discuss the three levers which should be front of mind for business in 2019. First, meaningful corporate commitments to human rights as business as usual; second, creative application of technology; and third, collaborative multi-stakeholder engagement.
Making a meaningful commitment to human rights as business as usual
How did we find ourselves here, with the scourge of modern slavery laid at the feet of business? The answer is both simple and complex. Ultimately, when the United Nations Guiding Principles on Business and Human Rights (UNGPs) were accepted by the international community in 2011, it marked a significant shift in how we understand the responsibility of corporations in managing negative impact on people. The UNGPs put business at the heart of responding to the harm that their activities might cause. The fact that many business models lack visibility of the source of goods and services is no longer an excuse for companies not to know about harms that may occur in their supply chains.
While it might seem overwhelming for those who have not yet engaged, corporate leaders are demonstrating that getting to know your business and its impacts is a platform for doing business better. Underlying these responses is a common foundation. Businesses are making public commitments to doing no harm, and specifically to respect human rights. For these commitments to be meaningful, they must live in the policies, standards and implementation plans of every business unit and function. Making respect for human rights business as usual is something to be progressively realized, but it is a lever that is absolutely in the control of business.
Creative and smart use of technology
There is no doubt that emerging technologies and new applications of existing technologies will disrupt our responses to systemic human rights issues. This comes with its own inherent tension – we know that the existing and emerging technologies which allow us to identify and trace patterns of potential abuse, can simultaneously cause or compound harm. Right now, we shape the questions we ask technology to help us to solve. We believe that core to those questions is ensuring that for every pain point we use these technologies to help us alleviate, we also build trust points to answer and verify the impact on people and planet.
The concealed nature of modern slavery practices, often far removed from group-level corporate governance, require new layers of visibility and analysis. The volume of data from across supply chains that business collects and generates is exponentially increasing. In the short term it is the smart and practical application of proven technologies such as data analytics that will provide us with new insights into where human rights risks lie hidden. Significant steps forward will be achieved by focusing on what is practical now rather than being seduced by the imagined future.
Collaborative multi-stakeholder engagement
Business cannot do this alone. Multi-stakeholder initiatives have been a hallmark of the progress businesses have made in collaborating with each other on sector-based responses, the development of platforms for holding and analyzing supplier data, and specific corporate programs to address particular areas of risk. While there is an important and healthy division in any accountable society between government, civil society, media and business, tackling modern slavery will require productive collaborative efforts.
Transparency will be the primary driver of trusted relationships. The regulatory reporting provisions in the UK and Australian modern slavery legislation, and other similar obligations in jurisdictions like France and in the US state of California, are ultimately designed to further transparency. More countries and territories such as Canada, Norway and Hong Kong SAR are discussing the introduction of modern slavery legislation, and 30 countries brought together by the UK on the sidelines of the United Nations General Assembly in 2017 made a similar commitment. While this is an accountability mechanism, it can also operate as a foundation for engagement. Businesses with strong stakeholder relationships will be able to develop a robust global response to human rights risk, which is the best preparation for meeting different reporting obligations. Engagement will drive learning, provide valuable data and promote public trust in business.
The end of modern slavery?
There is one shocking truth we need to remember in this conversation: we won’t end slavery completely. The realization of human rights requires constant vigilance: there will always be unscrupulous people and the instigation of new structures which cause harm. This is precisely why the project of identifying and responding to human rights risk has to be built into the systems and controls of business. It will require unwavering commitment, creative continuous monitoring, and engagement driven through trusted relationships to continue to prevent harm.
The levers to address modern slavery are at our disposal – we should pull every one of them. By choosing inaction you make a direct contribution to allowing slavery-like conditions to flourish unattended, unwatched and without redress.
 International Labour Organization and Walk Free Foundation (2017) Global estimates of Modern Slavery: Forced Labour and Forced Marriage. Available from: https://www.ilo.org/global/publications/books/WCMS_575479/lang–en/index.htm