Uniac - July 2022

7 What was also evident from this review and benchmarking exercise was the variable extent to which modern slavery was or was not explicitly referenced in the aforementioned policies, with some including no reference at all, leading to the question of to what extent the implications of the Act are appropriately reflected in some institutions’ existing policy frameworks. We would suggest referencing a smaller number of specific policies or procedures which focus on slavery and human trafficking is a more positive demonstration of appropriate action rather than a plethora of documents that contain no explicit, or only passing, reference to this area and do not provide an adequate response on the part of the business concerned. • due diligence processes in relation to slavery and human trafficking in its business and supply chains. All the statements reviewed as part of the benchmarking exercise addressed this area, but the variation in the level of detail was again notable in terms of the processes described. Coverage included a combination of suppliers and/or prospective employees. As well as institutions’ internal processes, a high proportion of statements also referenced affiliations with Electronic Watch (EW) who’s mission is to help public sector organisations work together, and collaborate with civil society monitors in production regions, to protect the rights of workers in their electronic supply chains, and Netpositive Futures, which enables suppliers to develop a sustainability action plan. Institutions appear to consistently state they undertake modern slavery due diligence checks as part of the supplier selection process, with some adopting a risk-based approach based on the potential risk and value of the proposed contract, whether that is based on institutions’ own checks or assurances provided by potential suppliers via tender documentation. We see this as good practice; however, in the main, these processes did not apply beyond tier one suppliers, where modern slavery issues are most likely to occur. Whilst the difficulties and challenges in doing so are recognised, this would provide institutions with amore detailed understanding of modern slavery supply chain risks and ultimately facilitate better management, mitigation and transparency. • the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk. The statements reviewed paint a picture of variable progress in this area. Some institutions’ processes appear to be relatively immature, with general reference made to future commitments and associated actions, but nothing specific by way of any formal risk assessment having already been undertaken. A number of institutions refer to having undertaken modern slavery risk analysis at a commodity and service or supplier level, either on an ongoing basis and/or as part of appointing a new supplier, which are then categorised into high, medium or low risk groups in order to prioritise the risk mitigation response. None of the statements reviewed contained references beyond first tier suppliers, which is of note given the

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