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Andrew Wallis:'Enlightened organisations are looking at their response to modern slavery'

06 February 2019 by Sonia Sharma

Andrew Wallis:'Enlightened organisations are looking at their response to modern slavery'

We talk to the CEO of anti-slavery organisation Unseen

Andrew Wallis is CEO of anti-slavery organisation Unseen, which provides safe housing and other services for survivors of trafficking. In addition to this, he runs the Modern Slavery Helpline, and works with businesses and others in the eradication of slavery. Andrew chaired the landmark Centre for Social Justice report ‘It Happens Here’, widely acknowledged as the catalyst for the UK Modern Slavery Act of 2015, and was awarded an OBE that year. Andrew will talk about the importance of effective supply chain governance in fighting modern slavery at ICSA's Charity Governance Conference on 8 March.

The Home Office recently sent letters to over 17,000 companies requesting them to register on the Modern Slavery Contact Database by November 2018. How do you think this will improve transparency within the supply chain and to what extent?

Any move to increase awareness of Section 54 of the Modern Slavery Act is to be welcomed but it was long overdue that the government began to insist on organisations complying with the legislation. However, awareness of the legislation is only one part of the equation, what really matters is what organisations are actually doing and that their annual Modern Slavery Statements are an accurate record of steps taken to tackle modern slavery in their business practices and supply chains.

What the letter from the government signals is that there is a step-change coming in terms of enforcement of the legal requirement to report, but also that government and public sector procurement will increasingly be looking at companies’ actual action on this issue. It is conceivable that companies failing to take the issue seriously could be precluded from frameworks in the future. So I view the letter as a warning shot to organisations telling them to take this matter seriously and proactively engage with the issue or face the inevitable consequences of a more punitive regimen.

Part of the government’s strategy to fight Modern Slavery revolves around the four ‘P’s’ – prevention, protection, prosecution and partnerships. How will this contribute towards good governance? Are there any segments of the strategy that stand out to you and what other further work do you think needs to be done?

The first thing to say is that, confusingly, there are two different sets of four Ps – one adopted by the UN (prevention, protection, prosecution, partnerships), and one developed by the UK government as its counter-terrorism strategy approach (pursue, prevent, protect, prepare), and it was the latter that the UK government applied to tackling modern slavery. One can draw one’s own conclusions about the appropriateness, effectiveness and wisdom of this. In part, the reason for this approach was that there is only one lens through which the issue is being looked at – that of organised criminality. While modern slavery obviously does often involve organised criminality, this is not always the case, and what is missing in this approach is that this is an economic issue as well.

So I would argue there needs to be a strategic refresh of how we tackle this issue. In terms of good governance, the only part of the act that intersects with this is Section 54 – Transparency in Supply Chains, which calls on organisations over the £36m turnover threshold to report the steps they are taking to tackle modern slavery in their business practices and supply chains, and by default in order to tackle this effectively includes good governance.

How do the four ‘P’s’ compare to the outcomes from the summit on safeguarding, abuse and exploitation in the aid sector which was held in October 2018?

I think the question is more about what we are trying to achieve – and for me, that is the eradication of modern slavery. Fundamentally that means a total systemic change in approach so that we tackle the structural issues that enable modern slavery to thrive. So yes, safeguarding, abuse and exploitation should be challenged but those are operational level issues.

“The benefits of complying are that firstly it de-risks your organisation and ensures due diligence”

The more difficult task is how do you tackle the systemic issues? We need to address the drivers of vulnerability and exploitation: the growing gap between the developed and developing world (and between rich and poor within countries); the detrimental impact of rampant and unchecked globalisation allied to the extractive profit model of capitalism that creates the perfect environment for forced labour abuses to take place; a procurement model that is only incentivised on profit margins; and society’s demand for cheap goods, services and labour.

When it comes to individuals who have ended up in exploitation then it is about what outcomes do we want for them – do we want them to thrive post them escaping their exploitation? This then includes your safeguarding issues but we should be focussed on more than just recognising someone as a victim, we should be ambitious for their success going forward. It is both a debt that society owes them but also the principal that a society is judged by how it treats the most vulnerable.

According to the Business and Human Rights Resource Centre briefing in April 2018, modern slavery elimination ought to be part of a broader approach to respect for labour rights, civil rights and community development. Do organisations need a more holistic approach to CSR, rather than a compliance-driven focus on slavery?

Yes and no. Modern slavery cannot be tackled in isolation but I would go further and say that the extractive profit model of capitalism which has been driving globalisation inherently undermines all these efforts and to effectively tackle these issues we need to transition to a sustainable profit model. We also need to highlight the value proposition or value chain more and also adopt the issue that business should be more than just wealth creation but should have proven societal benefits.

Also we need to help businesses see the economic case for doing the right thing. There is now a mountain of evidence of the positive impact of doing ‘good’ business. For example the application of the principle of decent work and a contextualised living wage all the way down the supply chains has enormous benefits both around quality assurance and productivity but also a wider societal impact which creates more resilient communities and reduces the vulnerability
to exploitation.

How can technology be implemented within the supply chain to flag up any potential risks? Are there any specific methods that you would be keen on utilising?

I think we are in the very early stages of how technology can help and enable us. Blockchain is one obvious technology that is gaining a lot of prominence and whilst it can prove the veracity of a product supply chain, it can’t tell us under what conditions something was farmed, manufactured, fished and so on. There will be no one silver bullet solution, there is rather a multitude of solutions tackling specific issues.

One solution Unseen have developed is an app for reporting directly into the Modern Slavery Helpline about concerns or suspicions people have about exploitation. Allied to this is a business hub on the Modern Slavery Helpline to inform businesses about the prevalence and typology of modern slavery where there is overlap with their operations. Then there is the work of TISCReport.org bringing the power of big data and data visualisation to inform organisations of where potential risks are as well as tracking how companies are reporting their modern slavery reports. Then technology can enable worker voices to be heard much more easily through apps like Labour Voices.

A group of some of the world’s leading technology companies have come together as ‘Tech Against Trafficking’ to look at how technology can play a role in the fight against supply chains and how different technologies can be utilised in the fight against modern slavery. This is important as we know traffickers are increasingly using technology as a means of recruitment, control and potential exploitation. 

The issue is this: is technology an enabler in tackling modern slavery and if it is, how do we utilise it to maximum impact? It must be an informed data-driven response.

Regulations have set the turnover threshold which obliges organisations to publish a statement each financial year at £36m. Is this an appropriate level? What would you recommend they do to implement good practice stemming from the Act? For you, what are the benefits of complying with the Act regardless of the threshold?

The threshold was set as it matched the threshold in the Companies Act for a large business and part of the original pushback against the legislation was that it would be a burden in business. The threshold level is almost immaterial as we have seen the expected ‘trickle down’ to businesses below the threshold as those above the threshold have asked their smaller suppliers to either prove compliance with the act or evidence that they don’t have modern slavery in their supply chains or business practices. To help implement best practice Unseen has both developed software to help organisations manage their risk and comply even though legally not required to as it enables an evidenced response to those requests.

Also, we have developed a continuous improvement program for those forward-leading organisations who want to effectively tackle the issues. Every organisation regardless of size has supply and procurement chains, as well as potential practices that need to be investigated in order to ensure there is no exploitation taking place.

The benefits of complying are that firstly it de-risks your organisation and ensures due diligence. Second, it aligns with the increasing transparency agenda, and third it future-proofs, as increasingly the millennial and Gen Z workforce want to both work in organisations that are aligned to their values and have a positive response to modern slavery and also realise their purchasing power. Finally, enlightened organisations are looking at their response to modern slavery as a positive opportunity to position their organisation for the future where transparency and ethics are the priority and it becomes mission critical to have more than just a nod towards these issues, they have to be priorities and practices of the organisation.

The charity Hope for Justice recently argued that companies who suspect labour abuse in their supply chain should work with suppliers to eliminate it rather than sever links with them. Other organisations adopt a similar stance. Given the influence which those with significant purchasing power potentially wield, do you agree with this position? How should they manage the risk to their reputation as they do this?

The context to this is that for many the only response to businesses found to be implicated in these issues is to ‘name and shame’. Unseen operate a policy of ‘name and fame’ those businesses who are actively tackling modern slavery and for us the fact a business has proactively found labour abuses and reported them should be welcomed as it shows they are looking for it and prepared to deal with it.

The truth is there probably isn’t a business that is not touched by modern slavery, directly or indirectly. So the issue is not ‘guilt’ nor ‘if’ you find it but ‘when’ you find it are you prepared to deal with it, make changes so it can’t happen again in that locale and what does restitution and remediation look like?

That said we also have to be pragmatic and move away from perfectionism or idealism. When it comes to labour abuses down the supply chain we have to acknowledge at the lower ends of the supply chain how much actual leverage do the companies at the top actually have or in the majority of cases, do they even know where their supply chains go.

So there needs to be a phased response. Map supply chains and then work collaboratively to bring leverage for change and then commit to principles of decent work and contextualised living wage throughout the supply chain. But this will take time as we are countering 40 years of rapid globalisation and supply chains elongating and becoming webs but it doesn’t have to take another generation to change, so we name and fame and then say go further and faster.

A Bill introduced into the House of Lords (currently at the second reading stage) would extend the Act to cover public authorities, and would require contracting authorities to exclude from a procurement procedure an economic operator which has not prepared a slavery and human trafficking statement. This seems to allow for the Secretary of State to publish a list of all commercial organisations, categorised by sector, that are required to publish a statement. What are your thoughts on this?
This is to be welcomed. In any country, the government is always the biggest procurer so if it holds itself to the highest standards and insists on those it does business with to do the same, this will have a step change impact.

The bottom line is the government should only do business with those companies who are actively tackling and evidencing what they are doing to tackle modern slavery.

As a taxpayer I do not want my taxes being spent with companies that are either enabling modern slavery or are not active in tackling it, and I’m sure many others feel the same. 

Interview by sonia sharma, editor of governance and compliance

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