Modern Slavery: Raising International Standards

Modern Slavery: Raising International Standards

If you’re engaged, enlightened, motivated, driven, mandated and fully supported by your organization, you will already have been looking hard, possibly for a long time, to identify human rights risks in your business operations and supply chains. You will have been finding those places in which human rights abuses are happening, or likely to be happening, and seeking out instances of modern slavery in all of its forms. It’s also highly likely that the harder you’ve looked, the more you’ve found. 

If this is you, great work; you’re part of an A-team bent on supporting, promoting and upholding human rights, and encouraging and guiding your organization to find its leverage points and act responsibly. After all, knowledge without action isn’t the aim here, is it?

Working Within Organizations

You’re likely to be working beyond your organization’s audit or compliance programs — although these are, of course, fundamental in assessing where risk lies, they are the bare minimum for businesses. With the Social Responsibility Alliance (SRA) Slavery and Trafficking Risk Template (STRT) open source and free to all, there is no excuse for doing nothing; and speaking from experience, it’s a template with power.

I’m sure you know — although not everyone seems to — that there is a world beyond all of this that requires your immediate and full attention. It’s a world that has decent work at its core and a victim-focused strategy at its heart. 

If your organization is committed to long-term sustainability, and to delivering back on any public commitments it’s made, alongside its raft of legal obligations, you will be enabled and encouraged to be at the coal face. You’ll be back to raw materials. For me that means back to holes in the ground from where our natural stone is sourced around the globe. And then, like me, you’ll be chasing that back from the ground up and through the various primary, secondary and tertiary processors.

You’ll also be paying close attention to the all logistics and transportation elements that form part of the supply chain; whether powered by human or animal, and whether on road, rail, water or in the air. And you won’t overlook the “open market” where your suppliers are likely to turn — without your knowledge — when they cannot get what they need from along the spider’s web of the visible, audited supply chain, and where your ability to track and trace is limited, if not confounded altogether. This may account for a small amount of the product that is part of the supply chain, but nevertheless it is now part of your supply chain.

Engaging the Landscape

You’ll likely seek the best possible independent partners — from intergovernmental and non-government organizations to UN agencies — that will have more chance of getting to the places you may find culturally or geographically hard to reach, and that know better than you or I how to get closer to the heart of the matter; either by merit, turn of phrase or deep knowledge as a country national. 

You may commission undercover human rights observations for nine months of the year that actively infiltrate your supply chain and that of the sector at large. If so, be prepared for powerful findings. You’ll build up a sprawling supply chain map that challenges your senses and a worker recruitment map to sit alongside it. And, as a reward for all of this, you will be faced with difficult to digest realities. 

Congratulations — this means you’re doing it well.

You’ll find issues. Most likely serious issues — the kind that are often hard to pin down and therefore even harder to solve. Few will be a matter of corrective action plans committed to paper and followed up remotely. Some will require full supplier engagement, while others will be a matter of education on both sides of the fence before the right time to engage the supplier is carefully chosen. 

Many of these issues will leach out way beyond the boundaries of the factory door, compound, farm, field, quarry or wherever they are found. They may lean toward the lack of implementation of the rule of law, corruption from low level to high level, the complexities of the domestic market confounding all efforts, the enmeshing of both formal and informal sectors with organized criminal activity, among other things. Even in seeking to articulate the issues with key actors in-country, you will be forced into an odd form of verbal thai chi where the words “modern slavery” or “prison labor” should not be uttered if progress is to be made at all.

Bringing Change Home

Back at HQ this hard-won knowledge will likely lead to difficult and sometimes turbulent discussions within your own organization. You may not be popular with everyone, but that goes with the territory, so don’t sweat it. The dynamic, tense and potentially creative spaces where procurement, commercial, human resources, sustainability, corporate social responsibility, human rights teams and others must ultimately elevate their thinking, draw on their most intense listening and refined communication skills and seek to find solutions that put people and decent work at their heart. 

It’s often here where the question of whether to stay or go, either from a particular supplier, region or country, will be tabled in one form or another — a question that is intrinsically linked to whether an organization will dig in and play its part in seeking to raise international standards, make a net positive impact and endeavor to be an “agent of world benefit.” (Tsao, 2019) 

Whether the organization will do nothing at all, advocate for responsible corporate citizenship, and, if necessary, move on to another supplier, region or country before moving on yet again.

Doing More 

Despite the grumblings of some regarding the UK Modern Slavery Act, what it has offered is a threshold for businesses to cross willingly and to engage with the spirit of the act rather than just the letter of the law. It has also forced a maturation of the language within the private sector regarding business and human rights, as well as provided the motivation for new and different conversations between very different actors.

I myself had not had such extensive cross-sectoral engagement, enhanced involvement with various law enforcement agencies or the opportunities for the extensive private sector strategic dialogue with my own government, or indeed those in other of our sourcing countries before this act provided the push and the platform. The growing number of similar pieces of legislation and instruments from around the globe have served only to increase pressure, pushing the private sector to look for opportunities to uphold international standards and making the need for education, action and engagement crystal clear.

So, how do you sustain yourself in this difficult space? A space, which on a good day, allows you to believe that you’re making some kind of difference, and, on a bad day, makes you think that even if you live to be 101 you will not live long enough to see any progress at all. 

Seek organizations that have a values match for you and are congruent in their dealings; find good colleagues; find amazing peers; share in confidence; share successes; share failures; engage in the dialogue; and know that there’s always more to know. Keep a strong back, soft front and wild heart (Brown, 2018), because your council will be called upon, and it counts because it has an impact. 

What kind depends on you.


Elaine Mitchel-Hill is an expert in responsible supply chains, sustainable procurement, labor rights and more. In her role at Marshalls plc, she develops human rights strategy and embeds this activity in Marshalls’ business operations. She is also an advocate of the United Nations Global Company (UNGC) and represents Marshalls at the International Labour Organization’s International Programme for the Elimination of Child Labour.

Elaine is speaking at Assent’s Insight conference in November 2019. To learn more about how you can join her and other industry leaders in Phoenix, AZ, visit the official event website


Laszlo, C. & Tsao, F. C. (2019). Quantum Leadership: New Consciousness in Business. Stanford, CA: Stanford University Press.

Brown, B. (2019) Dare to Lead. New York, NY: Random House.

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