Modern Slavery Policy

Version dated 01/07/2023

Background and Definition

Slavery is illegal in all countries yet today there exists a thriving, pervasive, highly profitable industry called ‘modern slavery’ with some 50 million people – a 25% increase in just the past five years - trapped and being forced to work in dehumanizing conditions for little or no pay.

A lack of supply chain transparency is the principal enabler of modern slavery. Increasingly complex, integrated global supply chains have made it virtually impossible to tell whether products stamped “Made in XYZ” have at some stage used slaves or underage children in producing them.

This lack of supply chain transparency has led to many companies in G20 countries declaring themselves ‘low risk’ for being too far removed from slavery to have any involvement in it. However, the G20 import over 80% of all slave-made goods* thereby sustaining the slavery industry.

The term ‘modern slavery’ in this policy is an umbrella term intended to encompass all forms of slavery:

human trafficking
slavery
servitude
forced labour
debt bondage
forced marriage
child labour

Policy Objectives

In 2015, all 193 Member States of the United Nations became signatories to UN Sustainable Development Goal 8.7 (‘SDG8.7’) to:

‘Take immediate and effective measures to eradicate forced labour, end modern slavery and human trafficking by 2030’.

SlaveCheck subscribes to SDG8.7 and commits to go beyond compliance and play our part in systematically eliminating modern slavery. To this end, we undertake to:

Ensure that our own operations remain at all times free of modern slavery;
Progressively build transparency in and product traceability through our global supply chains;
Guided by (B), make whatever supplier-based changes are necessary throughout our supply chains to achieve slave-free status as soon as possible but not later than 2030;
Participate in and/or contribute funding towards the evidencing of modern slavery situations in our supply chains but outside our direct operational control; and
Participate in and/or contribute funding towards the remediation and monitoring of any modern slavery situations identified in (D).

Voluntary Reporting Entity

SlaveCheck does not currently meet the revenue or other threshold that would make it a mandatory reporting entity under any anti-slavery legislation. However, to provide leadership in supporting SDG8.7, SlaveCheck has opted to become a voluntary reporting entity under the anti-slavery legislation in every jurisdiction where the company operates.

Modern Slavery Due Diligence System

As a voluntary modern slavery reporting entity operating globally, and to achieve our Policy Objectives described in Clause (2) above, we recognised the need to implement an effective, sustainable, modern slavery due diligence system which is:

Collaborative, partnership-based
Survivor-centric
Non-disruptive
Globally scalable
Auditable
Covers end-to-end supply chains
Viable (time and cost) for SlaveCheck and our suppliers
Continuously improving and evolving

Our four-part due diligence system consists of:

A free and simple modern slavery ‘clearinghouse’ for all Tiers of suppliers to connect and securely exchange the necessary transparency and product traceability data up and down our supply chains;
The system (UNSPSC®) which provides 'global best practice' in tracking products and services from source to end-consumer. For more information visit About the UNSPSC system;
A ‘collective intelligence’ collaboration management platform for engaging NGOs at scale, enabling them to bid for funded in-field solutions, crowdfunding those programs, project managing deliverables and monitoring the ongoing effectiveness of the solutions. For more information, see Solutions Platform.
Participation in a global integrated network of trusted victim voice portals, providing a systematic approach to engaging victims and providing trauma-informed classification and assignment as appropriate to one or more of law enforcement, prosecution, immigration, medical, human rights and community support services.

Training

As part of our due diligence system, all SlaveCheck personnel will undertake a modern slavery awareness programme which includes:

the various forms of modern slavery and how people can be held and exploited;
the scope of the issue and how it affects our organisation;
how personnel can identify the signs of modern slavery practices; and
responsibilities and process if workers suspect modern slavery.

Conduct of Our Suppliers

SlaveCheck requires existing and new suppliers to support us in pursuing our Policy Objectives as described in Clause (2) above.

As a condition of working with SlaveCheck, we require our direct suppliers to:

Confirm that your own operations are free of modern slavery by completing and having a Director sign the Self-Assessment Questionnaire (SAQ) in our due diligence system, or by some other agreed means;
Classify your products and services using the UNSPSC system menus in our due diligence system, or by some other agreed means;
Invite your direct or Tier-1 suppliers to our due diligence system as Free Users;
Using data and information from our due diligence system as a guide, progressively make whatever supplier-based changes are necessary throughout your supply chains in a timely manner to achieve slave-free status as soon as possible but not later than 2030.

Supplier Compliance and Non-Compliance

We will invite our direct or Tier-1 suppliers to our due diligence system as a Free User, which is sufficient for our suppliers to comply with this policy provided you comply with Clause 6 above.

SlaveCheck cannot use suppliers who don’t comply with this policy, unless there is no alternative compliant supplier, and only until there is an alternative compliant supplier, in which case SlaveCheck will switch to the new compliant supplier as soon as practicable.

*International Labour Organisation; Global Slavery Index

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