To some companies, developing an audit regime might seem like an overwhelming task. What’s the best place to start?
Our work starts where the strategic advisory finishes. Our clients will often have worked with consultants to identify high-risk countries and supply chain categories, and our job is then to dive into those.
What we have generally found to work best is to focus on what the expected outcome is going to be and then work back from there. For some companies with well-developed compliance requirements and supplier vetting, we might go straight to developing an in-depth audit process that covers all key risk areas and regulatory requirements. However, for those who are starting out in this process, a logical first step might be to conduct an independent Self-Assessment Questionnaire (SAQ) to help identify suppliers that merit deeper investigation.
Given that most companies caught by the Act are likely to be doing this kind of thing for the first time, what’s a reasonable goal to aim for over the next 12 months?
Most companies have now completed the basics and are either developing, or have already published, their modern slavery statement. So the next step is implementation! This means developing a plan to engage with high-risk suppliers. To keep companies on track, this should go beyond just pure auditing and include information sharing, training, and signposting a suitable consultant to help them, in turn, better understand their modern slavery risks.
It’s important to plan out how the company will track the implementation (and success) of each mitigation strategy. This could be through a further audit, or conducting desk-based assessments of actions taken and their impact – or a mixture of both.