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Modern slavery: why police organisations need to look internally

Former Derbyshire detective superintendent Paul Callum highlights the duty of care public sector organisations need to demonstrate with their supply chains in relation to the Modern Slavery Act.

Modern slavery: why police organisations need to look internally

Date - 7th November 2019
By - Paul Callum

The summer of 2013 changed my life and my career for ever. I met a man called Frank, who’d been exploited by an organised crime gang from Slovakia, promised a better life but instead duped into slavery, losing his wages and his liberty. Frank didn’t see his family for over two years.

So began Operation Atwood, a multi-agency investigation with multiple victims and multi-million-pound money trails, not to mention substantial prison sentences.

Roll on six years and modern slavery awareness has grown exponentially. Legislation has been introduced in many countries including France, Australia and the UK.

Since 2015 corporations with a turnover of £36 million or more have been required to report on what action they are undertaking to identify, manage and mitigate the risk of modern slavery in their supply chains.

They do this by writing and publishing a section (54) transparency in supply chain statement.

Reporting has been interesting to say the least, with many companies initially either not reporting or submitting very poor statements, many cautiously tip toeing through the six elements of the Act or on occasions, just reporting the areas they had been doing work on, ignoring other elements of the Act.

Many organisations treated the statement purely in “compliance” terms and as such really didn’t commit to a meaningful statement. (Compliance is achieved by having a statement, signed by the CEO and a link posted on the front page of the company website).

Transparency, as construed by the Act, is not necessarily a legal compliance issue, but is in fact a reputational and, more broadly, a governance issue.

Now in the third year of reporting, progressive corporate leaders have embraced section (54) as an opportunity.  An opportunity to showcase their company values, opportunity to highlight best practice and most importantly, opportunity to help vulnerable people and prevent exploitation.

In recent years we have seen police forces creating specific teams to tackle modern slavery in our towns and cities and we have seen a proliferation of multi-agency stakeholders creating modern slavery partnerships. The Gangmasters and Labour Abuse Authority (GLAA), a non departmental public body which investigates labour exploitation across England and Wales in partnership with police forces and the National Crime Agency, is growing in size, remit and reach.

In addition, the HMICFRS has conducted a thematic review of police forces and published the “Stolen Freedom” report.

All of which is absolutely to be commended and I would urge forces to continue this drive and commitment.

There is an anomaly, however. According to the Institute for Government, in 2015 public sector procurement was worth over £260 billion, some 13.6% of GDP and yet there is no requirement for these public bodies to report against section (54) of the Modern Slavery Act.

Keen observers and horizon scanners will have noticed that change is coming.

There is growing pressure for the police and public sector to report changes to the Public Contracts Regulations. The Modern Slavery Commissioner also has a strategy to “hold Chief Constables” to account for their business engagement.  Meanwhile an independent review of the Modern Slavery Act 2019 has recommended, “that section 54 of the Act should be extended to the public sector….”

Modern Slavery reporting isn’t just about the statement. The statement is the lens through which an organisation’s activity to safeguard against modern slavery will be viewed.

Former detective superintendent Paul Callum 

In fact, when I advise companies, I suggest that they should be conducting as much prevention and proactive activity as they can, which in turn will create information with which to “populate” the statement.

Public sector organisations will need to adopt a comprehensive strategy, a continuous improvement action plan and ensure leadership from the very top if they are to create a mature modern slavery management system.

Derbyshire Constabulary under the leadership of Peter Goodman, have done exactly that.

They have asked themselves “where are we vulnerable and how can we mitigate that risk?”

Already a progressive force, they have used section (54) to have a really good look at risk, threat and harm from modern slavery, not just in respect of organised crime gangs and the devastating effect they have on victims but also internally, in the same way that business has done.

Peter has conducted a comprehensive review of his risk along the supply chain, in the HR and procurement processes and in the way in which Derbyshire has engaged on the subject with businesses.

The force has completed a modern slavery statement and taken the view that this is the start of a journey, a continuous improvement journey which will see further developments as they begin to implement the comprehensive action plan that has been developed.

In the private sector there has been growing concerns over the integrity of supply chains for many years across a range of industries. One industry expert, Phil Shaw, who has spent over 30 years at retailers Walmart and Asda and more recently Global certification company SGS, before starting his own consultancy firm, believes we are at a critical point in the management of supply chains and urges industry to move past the "tick box" culture and recommends organisations adopt a "Beyond Compliance" approach, based on threat and risk. 

Phil states: "It is only when an organisation maps its supply chains and really understand where the threats from organised criminality lie, that they are able to properly mitigate that risk. Once you have begun this work you will be in a position to understand where your organisation needs to improve.

"Many private companies have used this early risk assessment to populate their modern slavery action plans and subsequently write a statement. The public sector have huge procurement requirements from the private sector and I am really pleased to see that progressive public organisations have begun to take heed and look forward to seeing many more public commitments to this agenda."

Paul Callum is the Director of Resilient World Solutions Limited, a Business Crime Consultancy specialising in, amongst other risk areas, Business Human Rights and the Modern Slavery Act.

Paul is working with Red Snapper Recruitment to help provide guidance to UK public sector organisations on: legislation, supplier codes of practice, due diligence and best practice processes. 

Please contact Luke Starling at Red Snapper Recruitment on  0203 119 3325 or luke.starling@rsg.ltd for further information.

https://www.justiceinspectorates.gov.uk/hmicfrs/wp-content/uploads/stolen-freedom-the-policing-response-to-modern-slavery-and-human-trafficking.pdf

https://www.instituteforgovernment.org.uk/explainers/public-procurement

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