Regulations

I hope I understand the question correctly regarding how to implement a Human Trafficking and Modern Slavery policy with your vendors. First, any policy you have for your vendors should reflect the standards the organization holds for itself. And should reflect the current regulatory requirements for the countries where you do business and where your vendors are located. The last part can be tricky for organizations with many offshore vendors.

Many organizations engage outside experts to assist with this process. The variations in regulatory requirements, the complexity of supply chains, and the accurate identification of risk factors coupled with the types of vendors present a real challenge for most organizations.

As a good starting point, you can develop or strengthen your vendor code of conduct to include explicit human trafficking and modern slavery prohibitions. As part of standard due diligence, you can also require your vendors to provide human trafficking/ modern slavery statements that describe the known risks for their industry and supply chains, their policies, mitigation actions, and enforcement. Adding modern slavery and human trafficking questions to your due diligence questionnaire will also enhance your efforts.

Human trafficking and modern slavery are serious issues. Any progress your vendor risk management program can make towards identifying and eliminating them is always good. But as regulatory requirements increase, you may find that engaging a professional firm to address the many technical and regulatory issues may be the best path forward.

I hope that helps, but I would love to hear from other members who have had experience with this issue.