Designers need to be on heightened alert for slavery in their supply chains.
In recent headlines, The Times and Sunday Times have levelled accusations of modern slavery failings at two well-known retailers. This follows recent statements by Rob Richardson, the Head of the Modern Slavery & Human Trafficking Unit at the National Crime Agency, which made it clear that the NCA is determined to "pursue offenders and protect victims" and "to identify and respond to the changing modern slavery and human trafficking threat picture as a result of COVID-19".
These kind of investigations are multi-faceted and often trigger investigations which go beyond modern slavery, such as minimum wage enforcement and immigration.
More than ever, businesses must be vigilant about their supply chains, and consider also how COVID-19 may have impacted their wider supply chain, which is sometimes hidden.
What should you be doing to protect your business and yourself?
You should conduct fresh risk assessments on your suppliers to establish how they have been impacted by COVID-19, as well as establishing their resilience and ability to respond in a crisis. You should also track how those in your supply chains are behaving and how they are treating their staff. Are there any red flags you should be picking up on?
The experience to date shows how reputations can be destroyed in minutes even without any charges having been brought. Apart from the bad press and collateral damage from stakeholder withdrawal, HMRC will name and shame companies and take proceedings against those who have not paid the minimum wage or National Living Wage to employees. Companies have to make restitution to employees going back six years and then there are penalties of up to 200% in addition.
Steps you should take if you are on the receiving end of a governmental or media investigation into your supply chain:
- Be ready. Time is of the essence when enquiries are made, and a considered and confident position is difficult to articulate if you do not know the facts. Have a crisis team of sufficient authority and capability in place, including your trusted advisors.
- Map your response. Consider the objectives and agendas of all parties, and formulate a clear strategy in response.
- Communicate. Consider your various stakeholders and audiences, and tailor communications to each of them. Staff and partners may well be contacted also, and need to know what they can and cannot say. How will investors react if they first read about the investigations in the press? Are you listening and responding to what customers and competitors are saying on social media?