Walking the line: How should businesses respond to Modern Slavery?

By Jack Kelly.

Modern slavery is one of the biggest challenges that faces the world today. It is no surprise, therefore, that the legislation – The Modern Slavery Act – was passed in 2015 to increase business awareness about this sensitive issue. In addition, the Act was designed to protect and support victims, ensuring that defense strategies were put in place to prevent slavery and trafficking.

Now in its third year how did the legislation affect the conversation about ethics in the business landscape?

We discussed the impacts of the Act with one of Europe’s leading food processor – ABP Food Group – and the global semiconductor manufacturer – NXP Semiconductors.

Vanessa Di Cuffa who is People Change Director at ABP Food Group and Eric-Paul Schat, Senior Director of Sustainability, Environment, Health and Safety at NXP Semiconductors addressed how the new legislation has impacted upon their own businesses, namely, food production and communication networking, respectively.

Similarly, they were both keen to highlight the significance of business transparency and the development of co-operative relationships with their supply chains. While they are positioned to hold the practices of supply chains accountable, this does not necessarily mean that they will refuse to carry on conducting business with them. Rather, as Eric-Paul Schat of NXP Semiconductors describes, it is ‘a continuous exercise’ to improve and modify current working conditions and the systems that hold these in place. Collaborative partnerships are essential in terms of supply and regulation, but ultimately, businesses have a moral and corporate obligation to protect the people that help this happen.

Methods to detect forced labour

One of the methods in which companies such as ABP Food Group, who developed their own internal business model, have responded to the legislation is to carry out regular risk assessments and interviews as a means to identify how employees are being treated in the workplace. In fact, the company takes the issue very seriously and consequently created a role, equivalent to a Modern Slavery Officer, that is tasked to perform these duties. Whereas NXP Semiconductors utilise a third party monitoring service in order to evaluate potential risks to workers. Furthermore, NXP Semiconductors construct workforce profiles, in particular, for migrant workers who

cannot speak English. This system allows them to protect unskilled workers and considers their position in the workplace. These tests are completed on an annual basis for both existing and new suppliers.

However, while these models seek assurances from workers and promote fair labour, there remains a difficulty in determining how supply chains run on a daily basis or perhaps, in extracting honest answers from the workforce. For instance, companies are likely to announce when they intend to visit and evaluate working conditions, so there is an opportunity for supply chains to hide bad practices. While NXP Semiconductors reserve the right to make unannounced visits, this rarely occurs. Thus, there is a case to argue that they are not receiving a true reflection of how their supply chains operate. Once more, there is a possibility that workers may feel under pressure to comment on their day-to-day working environment. Vanessa Di Cuffa from ABP Food Group confirmed that there are no guarantees to ensure worker satisfaction. Yet, the Modern Slavery Act does ensure that businesses were able to operate on a level playing field. This prevents rogue organisations from exploiting workers and effectively gaining more labour for less of an expense. Once more, the legislation is beneficial for companies that do demonstrate compassion and care for all employees she argues.

Ways to empower suppliers

Another way in which businesses have reacted to the legislation is to provide educational training to all workers, more specifically, training that is focused on spotting signs of Modern Slavery in the workplace. Employees of ABP Food Group are required to engage with online content that teaches and explains the symptoms of Modern Slavery but equally, suppliers are informed of such details. Companies are required to maintain a presence to suppliers to regulate and oversee practices. However, Vanessa Di Cuffa believes that there is increased difficulty in navigating around the new legislation. She said, ‘farmers are a special breed of people’ since they have no obligation to conduct or further continue business. Some of ABP’s suppliers are not contracted but may occasionally offer their services. Independent farmers would be required to understand and to agree to company terms and conditions that outline guidelines of Modern Slavery in the workplace.


In reflection, the Modern Slavery Act is a positive move to eradicate the possibility of abuse and inequality within the workplace. A host of companies and businesses are beginning to demonstrate a serious awareness of modern slavery and, proactively, are taking steps to underline responsibilities that corporations should have. However, the legislation has also left key decision makers in business puzzled.

What can they do to ensure that their practices and demands are suitable for both the company and the worker?

As implied by Vanessa Di Cuffa and Eric – Paul Schat, the need to strike a balance between corporate authority and worker satisfaction is critical.

Additional Information

If you are interested in this discussion, then please take a look at the Second Global Modern Slavery & Supply Chain Summit, where both Eric-Paul Schat and Vanessa Di Cuffa will speak alongside Senior Procurement & Supply Chain Practitioners from EDF, Twinings, Debenhams, JLL, Thai Union and more on the 14th November 2017: https://front-group.co.uk/modernslavery/

Found the article of interest? Then take a look at the upcoming Modern Slavery & Human Rights in Supply Chain Conference here.