CALLING ALL
READERS
We want to hear your employment
law issues. Send us your dilemmas to
feature here next month.
Email: chris.beck@markallengroup.com
Given such difficulties, many
employers instead use positive
financial incentives (such as
performance-related bonuses)
to seek to secure quality and
quantity performance levels.
Any agreed changes to pay
arrangements should be clearly
documented, including by
workers signing to confirm.
I’m a newly appointed
purchasing manager
at a large multinational
manufacturer. We source
components from all over
the world for our finished
product. On our website,
we declare that we are
against modern-day slavery.
However, I’ve found that one
component, which is sourced
from Pakistan, falls foul of
slavery regulations. I’ve raised
it with the board and they’ve
dismissed it as ‘competitively
priced’. What does the law
say about UK companies and
modern slavery, and what can
I do in this case?
The statement that is published
on your organisation’s website
will likely set out the steps
that the organisation has taken
during the financial year to
ensure that slavery and human
trafficking is not taking place
in the business or any supply
chain (or if no steps have been
taken, that fact). For larger
organisations, publishing this
statement is a legal requirement.
‘Slavery, servitude and forced
or compulsory labour’ and
‘human trafficking’ are criminal
offences and the organisation
should be transparent about
what steps it has taken to tackle
this; but this does not mean that
it must guarantee that the entire
supply chain is slavery-free.
It is not clear how you have
determined that the practice you
have discovered falls foul of the
legislation. However, where there
is a genuine belief or suspicion
that modern slavery is taking
place, it should not be ignored.
The appropriate action should
be tailored to the particular issue
and local circumstances, taking
account of what action would
produce the safest outcome for
potential victims. It may be that
engaging with local government
or law enforcement agencies
is appropriate, or alternatively
with the supplier, local support
agencies or industry bodies.
With ethical business practice
continuing to be in the spotlight,
businesses are under ongoing
pressure to take appropriate
action to address modern
slavery. Organisations who fail
to demonstrate appropriate
action and practical progress
will be exposed to risk, both
legally and operationally.
Significant reputational damage
can be quickly caused from
poor practices, including
through ‘naming and shaming’
campaigns led by pressure
groups. Ultimately, the risk to
the business is often considered
too high to simply ignore.
I would suggest that you
raise the issue with the board
again, highlighting the risks of
simply dismissing the issue and
encouraging the board to put
in place an appropriate plan.
The seriousness of the issue
could also be made clear by
explaining that, regardless of the
significance of the component in
the supply chain, modern slavery
– including aiding, abetting,
counselling or procuring a
human trafficking offence – is
a serious criminal offence that
can result in a jail sentence.
Know your law...
The Modern
Slavery Act 2015
consolidates
previous offences relating to
trafficking and slavery across
England and Wales. It covers all
accounts of human trafficking
and slavery.
www.manufacturingmanagement.co.uk 13
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