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© The British Standards Institution 2022

Published by BSI Standards Limited 2022

ISBN 978 0 539 16341 4

ICS 03.040

The following BSI references relate to the work on this document:
Committee reference G/1/3
Draft for comment 21/30431029 DC

Foreword

Publishing information

This British Standard is published by BSI Standards Limited, under licence from The British Standards Institution, and came into effect on 30 September 2022. It was prepared by subcommittee G/1/3, Modern Slavery, under the authority of Technical Committee G/1, Governance. A list of organizations represented on these committees can be obtained on request to their committee manager.

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0 Introduction

0.1 General

This British Standard provides organizations with guidance for managing modern slavery risk in its operations, supply chains and its wider operating environment. It uses a risk-based approach to help organizations understand the risk of modern slavery, to manage and reduce this risk as part of its legal and non-legal frameworks, and go beyond its legal and statutory duties. This risk management involves the systematic application of policies, procedures and practices to the activities of communicating and consulting, establishing the context and assessing, responding, monitoring, reviewing, recording and reporting the risk of modern slavery.

Modern slavery can be used to cover a set of specific legal concepts, including forced labour, debt bondage, forced marriage, slavery and slavery-like practices, and human trafficking. Modern slavery focuses attention on commonalities across these legal concepts and refers to situations of exploitation that a person cannot refuse or leave because of threats, violence, coercion, deception, and/or abuse of power.

NOTE 1 For further reading regarding why modern slavery is difficult to define, see Change in Rhetoric but not in Action? Framing of the Ethical Issue of Modern Slavery in a UK Sector at High Risk of Labor Exploitation [1].

Modern slavery practices sit at the extreme end of a continuum of exploitation, ranging from “decent work” to severe forms of labour exploitation, involving poor working and living conditions which harm human dignity. It is a criminal offence and a serious violation of people’s fundamental human and labour rights. The right not to be held in practices such as slavery, servitude and forced labour is echoed in core international frameworks, such as the UN Guiding Principles on Business and Human Rights (UNGPs) [2], the ILO Declaration on Fundamental Principles and Rights at Work [3] and, sustainable development goals (SDGs), including consideration of risks faced by humans as well as organizations.

NOTE 2 The International Labour Organization (ILO) defines “decent work” as the aspirations of people in their working lives, involving opportunities for work that is productive and delivers a fair income, security in the workplace and social protection for families, better prospects for personal development and social integration, freedom for people to express their concerns, organize and participate in the decisions that affect their lives and equality of opportunity and treatment for all women and men.

Organizations can cause, contribute or be linked to modern slavery practices. Regardless of the type or size, all organizations have a responsibility to understand modern slavery risks to their business and whether they can be implicated as a result of their activities, products and services, and business relationships.

Recognizing that organizations can vary in their understanding and response to the risk of modern slavery and that they can have different degrees of resources and leverage, this British Standard needs to be complemented by cross-functional expert knowledge tailored to the nature and industry of the organization and associated risks. Modern slavery is more than an organizational risk, it is a risk to human rights such that decision-making around modern slavery needs to be people focused.

This British Standard recognizes the changing nature of modern slavery and related human rights legal instruments both on national and international levels. It does not intend to replace these frameworks. It is the organization’s responsibility to comply with relevant legislation.

While this British Standard focuses on modern slavery, it recognizes that there are interdependencies with other sustainability considerations, such as climate change. This link is explicitly laid out in the concept of “Just Transition”, which challenges businesses to put people at the heart of climate mitigation and adaptation strategies. This British Standard has been constructed to complement that thinking.

NOTE 3 For further information on just transition, see the Paris Agreement 2015 [4].

This British Standard can be read in isolation; however, it has been written to allow organizations to integrate it into their system(s) or strategic approach to operational risks. It is intended to complement other activities that address the risk of modern slavery and related practices but not to replace them.

0.2 Modern slavery risk factors

Modern slavery practices can occur in any country or industry sector. However, there are some factors that can increase the risk of modern slavery, such as:

geography;
Countries or regions with poor labour market governance (e.g. restricted freedom of association and/or collective bargaining) or legal accountability for rights violations can present an elevated risk of modern slavery. Organizations need to take a risk-based approach to value chains reaching into territories in which these features are present.
labour market structure;
Countries, regions or sectors that are dominated by a single industry or a single or small number of employers can render workers more vulnerable as a result of a lack of employment choices.
Strong fluctuations in demand and supply for labour can increase modern slavery risks as the monitoring of workforce wellbeing, labour providers and recruitment channels become more challenging, and is often de-prioritized against the need for sufficient numbers of workers.
migration for work;
Low skilled work or poorly protected migrant workers can be at greater risk of modern slavery abuses. These can manifest themselves during the recruitment of workers in labour source countries and in their treatment at work in labour destination countries.
discrimination;
Discrimination based on ethnicity, gender, caste, tribal group, religion and other factors can make workers more vulnerable to modern slavery risk.
long and opaque value chains;
Highly complex global business models can lead to a lack of appropriate governance and oversight mechanisms and an elevated risk of modern slavery. Similarly, positive influence and/or leverage can be difficult to exert in business relationships, such as joint ventures.
corruption;
Corrupt business practices are often a root cause of modern slavery abuses.
vulnerable groups of people; and
There are particular individuals and groups that might be more at risk to modern slavery (see 0.3).
supply chain volatility.
The relationships in the supply chain vary between industry sectors. Shorter-term, frequently changing, and project-based relationships with no longer-term engagement or repeat business make it more difficult to achieve transparency or ensure responsible behaviour throughout the supply chain. Furthermore, strong fluctuations in demand and supply lead organizations to prioritize supply continuity and responsiveness over due diligence and compliance considerations. Ad-hoc and transactional relationships lower the ability to scrutinize and monitor potential modern slavery risks.

0.3 Vulnerable workers and groups

Certain groups might be more vulnerable to exploitation and modern slavery, including:

migrant workers;
While migrant workers are not inherently more vulnerable to modern slavery, factors such as migration status, language skills, knowledge of rights, and limited support and access to personal documents can contribute to their being at risk of modern slavery. Migrant workers who have limited access to basic necessities, such as accommodation and food can rely on their employer to provide these which contributes to their dependency and vulnerability.
women and marginalized workers;
Women and marginalized workers can be vulnerable to modern slavery due to harmful cultural practices, discrimination, marginalization, harassment, domestic and sexual violence, limited employment opportunities and poverty. These factors can increase the risk of exploitation and hinder the reporting of abuse or modern slavery practices in the workplace.
seasonal migrant workers;
Seasonal migrant workers in temporary migrant programmes can be at increased risk due to debt bondage (due to upfront migration costs and illegal recruitment feeds), barriers to changing jobs, discrimination, lack of pathways to permanent residency and barriers to accessing justice. These workers are less likely to have access to social security nets, such as unemployment assistance.
precarious/informal workers;
Workers on precarious employment contracts, such as zero-hours contracts and dependent self‑employment can experience a lack of guaranteed working hours. This creates insecurity and a higher risk of destitution.
young workers and children;
Young people aged between 15 to 18 years old in work can be vulnerable to physical, psychological or moral exploitation. Children in work under the age of 15, even when permitted by law, are particularly vulnerable to exploitation. They can often be more easily persuaded to lie about their age or working conditions to protect their income.
socially disadvantaged groups; and
Those who are socially excluded or in unstable social conditions can have limited economic opportunity and are typically more vulnerable. These groups can include those who are homeless, have disabilities or belong to a minoritized ethnic group.
workers operating in the informal economy.
Workers operating in any part of any economy that is neither taxed nor monitored by any form of government. Informal work can also often be found in domestic settings.

NOTE It is important to note that in some sectors and regions, men and women can be disproportionately affected, e.g. men are likely to make up a high proportion of modern slavery victims in the construction sector and women in domestic work or the textiles industry.

0.4 Factors influencing organizational responses to modern slavery

The motivations of organizations to identify and respond to modern slavery risks differ depending on the type of organization and the context in which they operate.

In addition to the organization’s own values, drivers for addressing modern slavery include:

legal and regulatory: compliance with modern slavery, labour and human rights standards; avoidance of financial and non-financial non-compliance costs; due diligence requirements and non-legal norms and mechanisms;
investment: responding to investors’ expectations (e.g. supporting responsible return on investment);
customer pressure: responding to customer and consumer expectations (e.g. sourcing sustainable and ethical goods and services);
stakeholder expectations: responding to increasing stakeholder expectations to take account of modern slavery risks; and
positive business reputation: opportunity to differentiate itself in the marketplace by holding itself up to the highest standards.

1 Scope

This British Standard provides organizations with guidance for managing the risk of modern slavery, including prevention, identification, response, remediation, mitigation, and reporting modern slavery in its operations, supply chains and its wider operating environment.

NOTE This applies regardless of whether state authorities have established mechanisms to abolish and prohibit such practices.

This British Standard is applicable to all organizations, regardless of type, size and nature of activity.

2 Normative references

3 Terms and definitions

4 Context of the organization

4.1 Understanding the organization and its context

4.2 Understanding the needs and expectations of stakeholders

4.3 Bribery

4.4 Legal and compliance teams

5 Leadership and commitment

5.1 Governance

5.2 Top management

5.3 Modern slavery policy

5.4 Roles, responsibilities and authorities

6 Support

6.1 Resources

6.2 Competence

6.3 Awareness

6.4 Communication

6.5 Training

6.6 Recording and reporting

7 Recruitment and employment relations

7.1 General

7.2 Recruitment: internal and external control

7.3 Worker empowerment

7.4 Terms and conditions of work

7.5 Occupational health and safety

8 Procurement and supply chain management

8.1 General

8.2 Responsible procurement: control of externally provided process, products and services

8.3 Procurement activity

8.4 Supplier engagement

9 Modern slavery risk management

9.1 General

9.2 Communication and consultation

9.3 Modern slavery risk assessment

9.4 Responding to modern slavery

9.5 Performance and evaluation

10 Improvement

Bibliography

BS 25700:2022

Organizational responses to modern slavery. Guidance

Current

Published:

30 Sep 2022