Guidance

PPN 02/23 - Tackling Modern Slavery in Government Supply Chains - Quick Reference Guide (HTML)

Updated 25 March 2024

Overview

This quick reference guide is aimed at commercial and procurement professionals involved in any stage of the commercial lifecycle. It summarises the key actions to be taken to ensure modern slavery risks are identified and managed, both on existing contracts and in new procurement activity.

The approach needs to be proportionate to ensure that the burdens in public procurement remain as low as possible - both for contracting bodies and for suppliers, especially small businesses and VCSE organisations.

What is Modern Slavery?

Modern slavery is a term used to describe the crimes of holding a person in a position of slavery, servitude, forced or compulsory labour, or human trafficking (facilitating a person’s travel with the intention of exploiting them soon after). These crimes exist across the world, including the UK. They can occur in any business sector, including those in government supply chains.

This quick reference guide, and government’s published policy and guidance, is concerned primarily with forced and compulsory labour, but actions taken to implement the guidance will impact all modern slavery risks.

1. Asses your risks
2. Manage and develop
3. Take action
4. Learn and improve

New Procurements

• Risk assessment: Identify which contracts are at high or medium risk of modern slavery based on industry type, complexity of supply chain, the nature of the workforce, context in which the supplier operates, type of commodity and supplier location.
• Pre-procurement & Specification: Design new procurements in line with the associated risk level including (if appropriate) application of the Social Value Model.
• Selection Stage: Consider the mandatory and discretionary exclusion grounds as set out in the Standard Selection Questionnaire. For high risk procurements, Part 1 and 2 declarations should be submitted for supply chain members.
• Award Stage: Apply tender response questions relating to modern slavery where they link to the specification, taking a proportionate approach.
• Contract Conditions: Consider including specific terms and conditions to strengthen contractual protection.

Existing Contracts

• Following contract award, continually work in collaboration with suppliers to address modern slavery risks and monitor progress. Put action plans in place to mitigate the risks identified.
• Map the supply chain of those contracts to establish specific risks. The Modern Slavery Assessment Tool (MSAT) from the Home Office can assist with this exercise.
• Work with the suppliers on high and medium risk contracts to mitigate the risks through strengthened contract management.
• Repeat this exercise at least annually for high risk contracts and at reasonable intervals for medium risk contracts.

Taking Action When Victims of Modern Slavery Are Identified

• If a victim of modern slavery has been identified, you should involve the law enforcement agencies. If a victim is in the UK and is in immediate danger, report it to the police by dialling 999.
• Work collaboratively with the supplier to address instances of modern slavery.
• Only terminate a contract as a last resort.

Training

• Provide training to commercial and procurement staff on modern slavery to raise awareness, help them to identify issues and ensure that suspected instances of modern slavery are handled correctly.
• There are a number of free and fee-based training resources available including the Chartered Institute of Procurement and Supply (CIPS) e-learning.

Useful Sources of Information

• The Walkfree Foundation’s Tackling Modern Slavery in Supply Chains guide.
• The Human rights due diligence framework by Ethical Trading Initiative
• The UN Guiding Principles on Business and Human Rights
• The Managing Risks Associated with Modern Slavery: A Good Practice Guide for the Private Sector, commissioned by the International Finance Corporation (IFC), CDC Group Plc, the European Bank for Reconstruction and Development (EBRD) and the UK Department for International Development (DFID)
• Protecting Human Rights in the Supply Chain ? a guide for public procurement practitioners by Professor Olga Martin-Ortega and Andy Davies, published in 2017 by London Universities Purchasing Consortium, the University of Greenwich, Advanced Procurement for Universities and Colleges and CIPS
• The Welsh Government’s Code of Practice: Ethical employment in supply chains