Are We as Compliance Professionals Really Fighting Modern Slavery and Human Trafficking?

...over 40 million people are trapped in conditions of forced labour or human trafficking. Of these, nearly 25% are children, and the majority are women and girls.

In today’s globalised economy, the fight against modern slavery and human trafficking is more urgent than ever. As compliance professionals, we sit at the intersection of business, ethics, and regulation, giving us a unique responsibility—and opportunity—to combat these heinous crimes. But the question remains: Are we truly doing enough?

The Scope of the Problem

Modern slavery and human trafficking are pervasive issues affecting millions worldwide. According to the International Labour Organization (ILO), over 40 million people are trapped in conditions of forced labour or human trafficking. Of these, nearly 25% are children, and the majority are women and girls. These crimes are often hidden within complex supply chains, making them difficult to detect and eradicate.

As businesses expand across borders, the risk of inadvertently supporting modern slavery grows. From forced labour in factories to exploitative practices in agriculture, human trafficking infiltrates various industries, making it a critical area for compliance oversight.

The Role of Compliance Professionals

Compliance professionals are tasked with advising organisations and developing risk control frameworks to mitigate risks and support adherence to laws and regulations, but our role extends beyond mere compliance. We are also are seen as the guardians of corporate integrity. However, the challenge lies in whether our efforts are effectively addressing modern slavery and human trafficking.

1. Due Diligence and Supply Chain Transparency

Supply chains are the Achilles’ heel of modern business. It’s not enough to look at your direct suppliers; you must scrutinise every layer to prevent exploitation.

One of the primary tools in combating modern slavery is conducting thorough due diligence within supply chains. This includes mapping out suppliers, identifying high-risk areas, and ensuring transparency throughout the process. But are we digging deep enough? Often, initial layers of the supply chain are scrutinised, while subcontractors and third-party vendors go unchecked. Comprehensive audits and regular monitoring are essential, yet they require resources and commitment that many companies may lack. Supply chains are the Achilles’ heel of modern business. It’s not enough to look at your direct suppliers; you must scrutinise every layer to prevent exploitation.

2. Risk Assessment

Conducting risk assessments is a fundamental part of compliance work. However, when it comes to modern slavery, are we assessing the right risks? Traditional client risk assessments for corporate clients often focus on building the compnay profile and obtaining supporting documentation, but human rights risks require a different approach. Integrating modern slavery into risk assessments means recognising the signs of exploitation and understanding the socio-economic factors that contribute to it - we need to be digging deeper and understanding our clients supply chains and operational models. We need this also adopted by other industry practioners including law firms , company secretarys, accountants and auditors.

Stat: According to a 2022 report by the Global Slavery Index, companies with insufficient risk assessment procedures are 60% more likely to have hidden instances of modern slavery in their supply chains.

3. Training and Awareness

Compliance professionals must ensure that employees, especially those involved in procurement and supply chain management, are trained to recognise and respond to signs of modern slavery. However, training often focuses on broader compliance issues, with limited attention to the specific nuances of human trafficking. Tailored training programmes that educate employees on the indicators of modern slavery can empower them to take proactive steps in preventing it.

Quote: “Awareness is the first step towards action. Training should not be a one-off but an ongoing process that evolves with emerging threats.” — Anna Richey, Director of Human Rights at Ethical Trade Initiative

4. Collaboration and Reporting

Fighting modern slavery requires collaboration across departments, industries, and even borders. Are we facilitating the necessary partnerships with NGOs, government bodies, and other organisations dedicated to eradicating human trafficking? Are Public Private Partnerships (PPPs) doing enough? Moreover, reporting mechanisms must be robust, allowing for the anonymous reporting of suspicious activities without fear of retaliation.

Stat: A study by the International Organisation for Migration (IOM) found that 75% of companies that actively collaborate with NGOs report higher effectiveness in tackling modern slavery.

Challenges and Barriers

While the role of compliance professionals is critical, there are significant challenges that hinder our efforts.

a. Lack of Resources: Compliance departments are often stretched thin, with limited resources to tackle the extensive issue of modern slavery. Conducting deep-dive audits, implementing training programmes, and ensuring continuous monitoring require time, money, and personnel that may not always be available.

Quote: “Without adequate resources, even the best-intentioned compliance programmes will fall short. Investing in proper tools and training is not optional; it’s a necessity.” — Jonathan Smith, Founder of Compliance Integrity Group

b. Complexity of Supply Chains: Global supply chains are intricate, with multiple layers of suppliers, contractors, and sub-contractors. Tracing the origins of products or services back to their source is a daunting task, often complicated by a lack of transparency and cooperation from third parties.

Stat: The Ethical Trading Initiative reports that 40% of companies find it challenging to trace their supply chains beyond the first tier, a critical barrier to uncovering forced labour practices.

c. Inadequate Legal Frameworks: While there are laws in place, such as the UK Modern Slavery Act and the California Transparency in Supply Chains Act, they often lack enforcement mechanisms and sufficient penalties to deter non-compliance. Furthermore, these laws typically apply to certain jurisdictions, leaving gaps in global enforcement. Effective enforcement of anti-slavery laws is essential. Without robust penalties and consistent application, regulations remain mere guidelines rather than true deterrents.

Are We Doing Enough?

Despite the efforts being made, it is clear that there is still much work to be done. The fight against modern slavery and human trafficking requires a more proactive and integrated approach, one that goes beyond ticking boxes and meeting regulatory requirements.

1. Enhance Transparency: We must push for greater transparency not only within our organisations but also across industries. This means advocating for stronger laws and regulations that require full disclosure of supply chain practices and labour conditions.

2. Leverage Technology: Technology can play a pivotal role in combating modern slavery. Blockchain, for example, can provide immutable records of supply chain transactions, helping to ensure transparency. Artificial intelligence and machine learning can also help identify patterns and red flags indicative of human trafficking.

Stat: According to a 2023 report by Deloitte, companies using advanced analytics and blockchain technology have seen a 50% reduction in modern slavery incidents within their supply chains.

3. Foster a Culture of Ethical Responsibility: Compliance should not be seen as a burden but as a core value of the organisation. Fostering a culture where ethical responsibility is ingrained in every aspect of the business can create an environment where modern slavery is not tolerated.

4. Strengthen Partnerships: Collaboration is key. Working with NGOs, law enforcement, and industry groups can help to pool resources, share knowledge, and amplify the impact of anti-slavery initiatives.

5. Measure Impact: Finally, we must measure the effectiveness of our efforts. Are our due diligence processes truly identifying and mitigating risks? Are our training programmes resulting in increased awareness and action? Regularly assessing and refining our strategies is essential to ensure we are making a real difference.

Conclusion

As compliance professionals, we have a moral and professional obligation to support efforts to combat modern slavery and human trafficking. While significant progress has been made, the complexities of these issues require us to continuously evaluate and enhance our approaches. By fostering transparency, leveraging technology, and promoting ethical responsibility, we can ensure that our efforts are not just symbolic but truly impactful in the fight against modern slavery.

The question isn't whether we can do more, but how soon we can start.