Introducing the Slavery and Trafficking Risk Template (STRT)
Recognizing the overlap of content among companies using customized templates to assess for risks of human trafficking and slavery in their supply chain, and the growing fatigue among suppliers fielding these different requests, the idea for a single standard survey was born. With the aim of providing companies a credible and robust template that would increase supplier response rates and improve data quality, a small group of organizations came together to craft a consistent set of questions. Their input provided the foundation of the STRT and paved the way for the development of the STRT Development Committee.

The STRT is a free open source template which companies can use to collect data on risks of slavery and human-trafficking in their supply chain. The tool aims to support companies with their anti-slavery and human trafficking programmes, and assist them in complying with both legislative reporting requirements and their own internal commitments and policies. The STRT pairs questions on legislative compliance (notably the US Federal Acquisition Regulation Final Rule on Combatting Trafficking in Persons (FAR), the UK Modern Slavery Act, and California Transparency in Supply Chains Act) with screening for risk of slavery and human trafficking, enabling companies to gain visibility into their suppliers’ policies, practices and procedures. In doing so, companies are able to effectively assess their exposure to slavery and human trafficking related risks in their supply chain and identify areas for improvement which they can use to inform their own risk mitigation action.

The STRT draws inspiration from the hugely successful Conflict Minerals Reporting Template, particularly in terms of format and style, but focusses on slavery and human trafficking in supply chains. The STRT can be differentiated from other tools on the market, including the EICC tool, across a number of factors. Principally, the STRT, unlike the EICC which is offered to EICC members only, is publicly available and does not require companies to submit completed survey responses to an external body to assess risk. This also gives the STRT flexibility – by allowing for configurable risk scoring the STRT enables companies to implement their own algorithms based on their needs, risk tolerance and priorities.

The STRT is concise, consisting of only 20 questions, and positions itself as a universal single standard tool for the collection and sharing of human trafficking and compliance data across all industry supply chains. As a multilingual tool available in English, French, Spanish, Portuguese, German, Chinese, and Japanese, the STRT supports global supply chains and enhances response quality internationally. The STRT is in Excel format and is available to download free of charge at the Social Responsibility Alliance website.

The template is housed by the Social Responsibility Alliance (SRA), an initiative focused on providing companies with the open-source tools, resources, and support they need to build socially responsible supply chains through the collection of responsible sourcing data. Found within the SRA, the STRT Development Committee is a multi-stakeholder, consensus-based consortium of organizations responsible for maintaining, reviewing, and revising the STRT.

How does the STRT help companies in countering the risk of slavery and human trafficking in their supply chains?
A key challenge for companies in tackling risks of slavery and human trafficking in their supply chain is a lack of visibility. The STRT enables companies to identify risk at an individual supplier level, often after using broader jurisdictional or industry-wide risk indices. This supports companies in building a granular data matrix of their supply chains, giving them visibility into their supply chain and empowering them to take targeted action where required.

By providing companies with a succinct and standardised template useable across all industries and geographies the STRT aims to alleviate supplier fatigue caused by completing different but equivalent forms for distinct clients or other enquirers. Suppliers with clients using the STRT are able to complete a single template and share the data across their client base. This reduces the administrative burden on suppliers, improving response rates and data quality as suppliers gain familiarity with the tool, and consequently heightening supply chain visibility for companies.

The STRT also supports companies with supplier engagement and building constructive dialogue with suppliers to tackle risks of slavery and human trafficking in their supply chains. In using the STRT, companies engage suppliers in their risk assessment process, raise supplier awareness of these risks and company efforts to address them. Engaging suppliers in this way supports capacity building and encourages them to take ownership in improving their policies, procedures and practices in countering risks of slavery and human trafficking.

Why are companies turning their attention to slavery and human trafficking related risks in their supply chain?
One of the primary motivations for companies has been new and emerging legislation targeting slavery and human trafficking in supply chains. The UK Modern Slavery Act in particular has galvanized company action. It has also inspired other jurisdictions around the world, such as Australia, to consider instituting similar legislation.

In addition to this, a significant expansion in the data available on slavery and human trafficking has revealed its scale. Recently released reports show that modern slavery is a global problem, with over 25 million people in forced labour, 16 million of those in the private sector.[1] Forced labour in the private economy is estimated to generate $150 billion in illegal profits per year.[2]

As more data emerges about the prevalence of slavery and human trafficking in supply chains, stakeholders, in the form of shareholders, investors and consumers, are increasing pressure on the private sector to take action. Companies are also better informed and consequently increasingly concerned, with recent research finding that 71% of companies believe modern slavery is likely to be occurring in their supply chains.[3] The STRT is a tool for companies to try and effect change within their own supply chains, in a way which best fits their own processes.

Compliance with non-financial obligations more broadly is being considered increasingly important by business – heightened concern regarding the risk of slavery and human trafficking in supply chains is part of this global trend. Big market players are taking highly publicised steps to eradicate slavery and human trafficking in their supply chains. This sets a trend, falling behind creates significant reputational risk, propelling a market shift towards greater compliance. As consumers become more focussed on the ethical credentials of companies, they become increasingly powerful differentiators between companies, giving brands focusing on ethical supply chains an edge in the market.

After sending out the STRT, what are the next steps a company should take?
Companies should review the STRT data and assign their suppliers risk scores to inform follow-up risk mitigation action. A guide on scoring STRT data is forthcoming from the STRT Development Committee, and will include guidance on generating a range of different risk scores, including compliance with FAR. This data should help companies tailor their risk mitigation activities, either by liaising with individual suppliers to isolate and mitigate risks or by effecting change at a procedural level.
STRT data should inform next steps, be that to update the code of conduct, to introduce new clauses into supplier contracts, conduct on-site audits or otherwise.

Conclusion
Although tracking usage accurately is difficult, as most companies will be downloading the template and circulating it across their supply chain themselves, the Development Committee has been able to identify that over 3,000 suppliers are using the STRT and have received requests to complete the STRT. It is likely that real figures are significantly higher.

Feedback is always welcome (the STRT website provides a feedback process), and the STRT Development Committee is working to develop additional resources to assist companies to identify, assess and mitigate risks of slavery and human trafficking in supply chains using the STRT– watch this space!

 


[1] International Labour Organization and Walk Free Foundation, Global Estimates of Modern Slavery: Forced Labour and Forced Marriage, 2017. Available at: http://www.ilo.org/global/publications/books/WCMS_575479/lang–en/index.htm.
[2] Ibid.
[3] Ashridge Executive Education, Hult International Business School, Corporate approaches to addressing modern slavery in supply chains: A snapshot of current practice Available at: https://www.ashridge.org.uk/getattachment/Faculty-Research/Research/Current-Research/Research-Projects/Corporate-approaches-to-addressing-modern-slavery/Modern-Slavery-v3-named.pdf
[4] Richard Adams, Marketing Week, 1997. Available at: https://www.marketingweek.com/1997/05/22/the-power-of-ethical-branding/

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