In February I was very pleased to launch the modern slavery toolkit for the construction supply chain. This had been developed in cooperation with Stronger Together, which had worked with the retail sector to develop a toolkit for that sector.
As construction is part of the retail supply chain, it made sense that there was some cohesion between the toolkits, but also that one should be relevant to construction.
Part of the product is a video relating a true story and giving an insight into how modern slavery could manifest itself in construction. What the video highlights, though, is the vital role ordinary site-based staff have in identifying labour exploitation and then acting on it.
It is important to realise that the reputation of the firm and its clients rests on site-based staff and their preparedness to identify an issue and then have the confidence to deal with it – even if it may have an impact on production.
Being proactive and being seen to be proactive has to be the best way to convince others – especially those in government – that the industry both understands the issues and has the resolve to tackle them.
The irony of the Modern Slavery Act 2015 is that while it is the directors that have to make the public statement, it is the people at both the bottom of the organisation and supply chain that are crucial.
It is not easy to make a meaningful statement without having some idea of the impact of the policies in place. As a recent report by Ergon Associates stated when it carried out a review of the statements made by companies in the construction and construction materials sector: “Business structures and policies relating to modern slavery tend to be dealt with in most detail, whilst other areas (risk assessments, monitoring, training, remedial action etc) are either covered minimally or not at all”.
So a year after the reporting requirements came into place it is probably fair to say that the jury is still out as to whether the industry has fully understood the ramifications of the Modern Slavery Act and embraced the obligations imposed. It’s the long tail of the supply chain that makes effective reporting difficult.
But there is a cause to be optimistic. The penny seems to be dropping at last. We have been approached by an advisor to a small firm that is outside the threshold for reporting. It is a supplier to a construction company that is within the reporting threshold and has been asked to provide information to the bigger company on the steps it is taking to tackle exploitation.
The threshold for reporting is a bit of an illusion as eventually everyone in a supply chain will end up having the means to report, whether they have to or not.
But, going back to the video, I am pleased to say that the hero is the site manager, who by being alert and questioning identified the abuse. To see the video, go to this link: http://bit.ly/2oePcSt.
Further details of the toolkit can be found here.