How confident are you that your organisation has taken all possible steps to reduce the risk of modern slavery? Researchers in Australia set out to discover how a housing association managed modern slavery risks, and to establish ways of reducing those risks.
Researchers Tracey Dodd, James Guthrie and John Dumay point out that modern slavery is prevalent in the international construction industry. The industry is vulnerable in part because supply chains often mean that use of materials such as bricks and wood is several steps removed from their production.
They worked for two years with an unnamed Australian housing association with a significant development programme on mapping existing modern slavery controls and devising new approaches to strengthen the association’s response.
The association already had policies such as its mission statement, code of conduct and whistleblowing policy. During the study, it introduced a new procurement policy and reporting procedure and undertook training at all levels for staff, to raise awareness of modern slavery and how to mitigate the risk of it.
Crucially, the association worked with contractors and suppliers to increase their understanding of modern slavery and compliance with its own new policies. An ‘indicator checklist’ helped to identify risks with suppliers and monitor their performance.
The team identified supplies that carry particular risk of being associated with modern slavery, particularly bricks, gravel, granite, iron (steel), rubber, stone and timber. They then developed an ethical supplier list with more than 500 suppliers that had gained international certification. The association expected its suppliers would source materials from the list, but this was not exclusive: they recognised that other sourcing could also be ethical. But suppliers were expected to show they had sought further information from such materials sources.
Where contractors hadn’t provided information on their own actions to reduce the risk of modern slavery, interestingly the association did not exclude them from contracts. Instead it worked with them, placing the onus on its own staff to engage and educate the contractors to improve their practices. Results compliance could then be built into individual contracts.
Similarly it didn’t bring modern slavery into its risk register or publish due diligence on the topic. Instead, a lower cost option was adopted whereby senior staff were expected to identify and mitigate modern slavery risks using the new tools.
The research found the combination of increased awareness and expectation of action by staff, together with formal policies and procedures, significantly reduced the risk of modern slavery occurring either in the organisation or its construction supply chain.
Management controls and modern slavery risks in the building and construction industry: Lessons from an Australian social housing provider https://bit.ly/3tQn611
