FWithout visibility into your supply chain, you could be unknowingly funding the continuation of modern slavery practices. While currently, regulations enforcing supply chains free of human exploitations aren’t as developed as those addressing cybersecurity risks, this is expected to change in the near future as pressures mount for regulatory bodies to increase their emphasis on Environmental, Social, and Governance (ESG) regulations.
To help you develop a supply chain management strategy optimized for the incoming wave of ESG regulations aimed at preserving human rights, this provides a questionnaire template for performing human trafficking and modern slavery due diligence when onboarding a new third-party vendor.
Learn how UpGuard streamlines Vendor Risk Management >
What Is Modern Slavery in The Supply Chain?
In the context of supply chain networks, modern slavery is any practice of human exploitation with the purpose of advancing supply chain processes.
There are three primary categories of supply chain modern slavery. It’s important to understand the difference between each type to ensure your modern slavery vendor questionnaire explores all possible avenues of potential modern slavery risks in your supply chain.
- Forced Labor - When adults are forced to work for little or no pay, usually under the threat of violence either to themselves or a loved one.
- Child Labor - Any form of forced labor involving children.
- Debt Bondage - When humans are forced to work in order to pay off fees associated with gaining employment (recruitment fees). Enslavers purposely target vulnerable humans desperate for employment. As a condition of their employment, workers sign contracts they don’t understand, which legally binds them to work until their recruitment fees are paid off. Employees ensure this outcome is never achieved by continuously fabricating reasons to keep expanding the overhead costs being paid off by the minimal wages of the employee.
Debt bondage is the most common category of modern slavery.
For further guidance on how your organization can join the fight to end modern slavery in the supply chain, refer to the resources provided by these anti-slavery organizations:
Important Modern Slavery Regulations You Need to Be Aware of
Before implementing a policy for reducing the risk of modern slavery, you need to be aware of all current regulations aiming to eradicate this threat in supply chains. Currently, there are X major regulations addressing modern slavery risks in supply chains (each item is linked to a resource with further information)
Many of these regulations have been enacted as recently as 2023, which indicates how quickly this regulatory sector is growing. As this list is very likely to grow, you should keep an eye on sprouting ESG regulations expanding the scope of your compliance program.
- German Supply Chain Act 2023 - Enforces vendor due diligence obligations to reduce modern slavery risk factors. It covers the complete scope of supply chain management, including labor code of conduct, employment conditions, child labor, etc.
More information about the German Supply Chain Act 2023 >
- France Duty of Vigilance Act 2017 - Only applies to large French organizations with 5,000 employees in France, or 10,000 globally. Companies are required to disclose the impact of their activities on people and the planet annually in public vigilance plans.
More information about the France Duty of Vigilance Act 2017>
- UK Modern Slavery Act 2015 - Consolidates previous offenses related to human trafficking and slavery. To comply, in addition to modern slavery statements, UK companies are expected to disclose their due diligence efforts to demonstrate efforts to ensure a clean supply chain.
More information about the UK Modern Slavery Act 2015 >
- Norwegian Transparency Act 2022 - Expacts large companies to be aware of human rights violation risks in their own supply chains.
More information about the Norwegian Transparency Act 2022 >
- EU Corporate Sustainability Due Diligence Directive - Outlines supply chain monitoring expectations for the prompt identification of modern slavery risks.
More information about the EU Corporate Sustainability Due Diligence Directive >
- Swiss Ordinance Act 2023 - Enforces transparency about the sourcing of minerals from regions prone to child labor exploitations.
More information about the Swiss Ordinance Act 2023 >
- Australian Modern Slavery Act 2018 - Requires entities in Australia with a revenue of at least $100 million to provide an annual report of their supply chain’s modern slavery risk exposure.
More information about the Australian Modern Slavery Act 2018 >
- Canadian Forced and Child Labor in Supply Chain Act - Coming into effect on January 1, 2024, the act forces affected businesses to provide a report on steps taken to reduce forced labor risks in their supply chain in the previous financial year.
More information about the Canadian Forced and Child Labor in Supply Chain Act >
- Uyghur Forced Labor Prevention Act - Aims to punish companies with supply chains supported by child labor in the Uyghur region of Western China.
More information about the U.S. UFLPA >
- Global Conflict Minerals Legislation - This regulation aims to mitigate the financing of armed conflicts and the risk of forced human labor commonly associated with the trading of tin, aluminum, tungsten, and gold.
More information about the Global Conflict Minerals Legislation >
You don’t need to be bound to any of these regulations to perform modern slavery due diligence in your supply chain.
The mitigation of modern slavery risks in your supply chain shouldn’t be triggered by a regulation. Your compliance program should take the initiative of stemming these threats. Not only will this ease the burden of compliance when your organization inevitably becomes affected by an ESG regulation, if you’re a vendor, the resultant reduction in your risk profile will give your business a significant competitive advantage - especially when evidence of your supply chain cleanliness (in the form of completed self-assessment questionnaires) is published on a Trust Page for prospective partners to find.
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Vendor Due Diligence Template: Modern Slavery in the Supply Chain
Use this questionnaire framework as a template for mitigating modern slavery risks during the procurement and onboarding processes of your vendor lifecycle. For a questionnaire mapping to risks as significant as modern slavery, response options should be more than just Yes No. Your questionnaire should accommodate for evidence provided as separate documents, such as certification schemes and audit reports. As such, a vendor questionnaire management solution, such as UpGuard, is a more convenient option for distributing questionnaires to entities in your supply chain. Solutions like UpGuard also accommodate for customization requirements, allowing you to tailor your modern slavery questionnaire to the unique risk mitigation objectives of your business.
Learn more about UpGuard’s security questionnaires >
Supplier Contact Details
- Organization Name
- Organization Address
- Parent Company
Contact Person Details
- Full Name
- Phone Number
- Date of Questionnaire Completion
Regulation Details
- List all of the modern slavery regulations your organization is required to comply with, for example, Modern Slavery Act 2018.
- Attach Modern Slavery Statements for all listed regulations. Also, include any relevant supporting documentation.
When supporting documentation is supplied, please indicate the question number it applies to.
1. Do you have a person or department responsible for overseeing modern slavery risks in your supply chain?
- Yes
- No
1 (a). If you answered Yes, describe the responsibilities of the person or team.
- Free Text Field
- Ideally, also provide supporting documentation
2. What is your degree of supply chain visibility?
- High
- Moderate
- Developing
2 (a). Explain why you choose this option. Attach relevant documentation to support your reasoning.
- Free Text Field
- Ideally, also request supporting documentation
3. Do you have policies in place to mitigate the risk of modern slavery in your supply chain?
- Yes
- No
3 (a). Provide details about these policies and attach copies of them.
- Free Text Field
- Ideally, also request supporting documentation
4. Do you have solutions in place for monitoring compliance with these policies?
- Yes
- No
4 (a). If you answered Yes, provide details about this software solution and explain how accuracy is ensured.
- Free Text Field
- Ideally, also request supporting documentation
4 (b). If you answered No, explain how you ensure compliance with each policy.
- Free Text Field
- Ideally, also request supporting documentation
5. Do offer modern slavery awareness training in your organization?
- Yes
- No
5 (a). If you answered Yes, how often does this training occur, and how do you test its effectiveness?
- Free Text Field
- Ideally, also request supporting documentation
5 (b). If you answered Yes, provide details of the program curriculum.
- Free Text Field
- Ideally, also request supporting documentation
5 (c). If you answered Yes, explain who is included in this training (roles of staff, departments, etc).
- Free Text Field
- Ideally, also request supporting documentation
5 (d). If you answered No, explain how you ensure modern slavery risk awareness in the workplace.
- Free Text Field
- Ideally, also request supporting documentation
6. Do you send your third-party vendors a modern slavery questionnaire as part of your due diligence process?
- Yes
- No
6 (a). If you answered Yes, explain the details of the questionnaire and attach a copy of it.
- Free Text Field
- Ideally, also request supporting documentation
6 (b). If you answered Yes, explain how you ensure response accuracy.
- Free Text Field
- Ideally, also request supporting documentation
6 (c). If you answered No, explain how your modern slavery risks are monitored during your vendor onboarding processes
- Free Text Field
- Ideally, also request supporting documentation
7. Are you aware of any substandard working conditions in your supply chain?
- Yes
- No
8 (a). If you answered Yes, provide details.
- Free Text Field
- Ideally, also request supporting documentation
9. List all of your due diligence processes for mitigating modern slavery risks in your supply chain. Include all software solutions, activities, corporate partnerships, etc.
- Free Text Field
- Ideally, also request supporting documentation
10. Does your supply chain include any organizations that have been accused of benefiting from modern slavery, either directly or indirectly?
- Yes
- No
10 (a). If you answered Yes, provide details.
- Free Text Field
- Ideally, also request supporting documentation
11. Does your supply chain have any associations with regions prone to child labor exploitation or any other types of modern slavery?
- Yes
- No
11 (a). If you answered Yes, provide details.
- Free Text Field
- Ideally, also request supporting documentation
12. Has your organization ever been accused of benefiting from modern slavery, either directly or indirectly?
- Yes
- No
12 (a). If you answered Yes, provide details.
- Free Text Field
- Ideally, also request supporting documentation
13 (b). If you answered No, how would you respond to such an allegation? What evidence would you provide to disprove it?
- Free Text Field
- Ideally, also request supporting documentation
Mitigate Modern Slavery Risks in Your Supply Chain with UpGuard
UpGuard’s library of security questionnaires includes a modern slavery questionnaire to support due diligence in this critical risk category during vendor onboarding. With its custom questionnaire builder feature, UpGuard gives compliance teams the option of adapting each of its questionnaires to the unique risk management objectives of the organization.
UpGuard’s questionnaire customization feature keeps your modern slavery questionnaire always open to adaptation to emerging modern slavery regulations, ensuring its ongoing relevance.
Watch this video to learn about UpGuard's custom questionnaire builder feature.
