Detecting and remediating modern slavery in supply chains: a targeted audit approach

Figures & data

Table 1. Summary of participants.

Organisation	Role	Mnemonic
Buyer A	Head of Ethical Trade	BA1
	Head of Sourcing	BA2
	Corporate Responsibility (CR) Manager UK	BA3
	Corporate Responsibility (CR) Manager Asia	BA4
	Corporate Responsibility (CR) Officer Asia	BA5
	Corporate Responsibility (CR) Officer Asia	BA6
	Researcher	BA7
Buyer B	Head of Corporate Responsibility (CR) Asia	BB1
NGO A	Capability Building Manager	NGOA1
	Programme Manager	NGOA2
	Translators x 4	NGOA3 to NGOA6
Supplier	CEO	S1
	Chief Sales Officer	S2
	HR Pay Managers	S3
	Documents Manager	S4
	Internal Auditor	S5
	Internal Translator	S6
	Workers x 23	S7 to S30

Table 2. Audit summary.

Day 1

Pre-Assessment Meeting with Audit Team Management & Supplier Management Ensured the supplier was clear on the structure of the audit and plan for the week. Pre-audit assessment questions.

Audit Team Preparation Meeting Ensured the audit team were clear on the structure of the audit and plan for the week.

Day 2

Team 1 Management Interviews Conducted a group interview with middle management focussed on the following: Recruitment, selection and hiring including the use of labour agencies. Corresponding documentation and worker files.

Team 2 Documents Review Reviewed the following: Company policies Employment contracts Documentation and records Any retained employee property

Team 3 Worker Interviews Interviewed a large sample of workers, skewed towards migrant employees focussing on the following: How workers were recruited Worker documentation Working conditions Social habits

Day 3

Team 1 Management Interviews Conducted a group interview with middle management focussed on confirming any open issues and requested any additional documentation to support the findings.

Team 2 Worker Interviews Interviewed additional workers. Particular focus was given to any open issues, or document irregularities that required clarification.

Day 4

Closing Meeting Presentation of audit findings (including any areas of good practice) to the supplier’s management team.

Day 5

Buyer A Reflections Meeting Final reflections of audit process.

Table 3. Summary of key data collected.

Data	Volume of data
Audio Recordings	62 pages of transcripts
Diary Notes	63 pages
Audit Protocol (Researcher Version)	7 pages
Buyer A Internal Audit Protocol	8 pages
NGO Findings and Recommendations Report	21 pages
Buyer A Modern Slavery Report 2017	26 pages
Buyer A Modern Slavery Report 2018	32 pages
Modern Slavery Toolkit Development	15 pages
Follow-up Remediation Interview Notes	18 pages

Table 4. Categorised audit findings.

Audit findings
Inadequate Procedures to Detect or Avoid Modern Slavery	Indicators of Modern Slavery
7 indicators categorised as follows: Recruitment Process and Policy (6) Inadequate Grievance Procedures (1)	8 indicators categorised as follows: Payment of Recruitment Fees (1) Human Trafficking (2) Limited Freedom of Movement (4) Restricted Access to Wages (1)

Day 1: Audit preparation

Pre-assessment meeting
Location: Hotel	AM
Attendees Buyer A: BA1, BA2, BA7, NGO A: NGOA1, Supplier: S1, S2, S3
Overview given of audit process/ schedule- focus on end-to-end recruitment process, employment cycle and robustness of Supplier system. Presented as learning experience for both parties. Information about legislation kept brief. Advised audit would include identification of areas to mitigate risk. Advised audit would help to form Buyer A policies. NGO A clarified some details provided in pre-audit assessment form – brief discussion of recruitment process. Master list of employees and attendance list requested for next day. Buyer A and NGOA asked Supplier if they had any concerns.
Buyer A preparation meeting
Location: Hotel	PM
Attendees: Buyer A: BA1-7, NGO A: NGOA1
Overview given of audit process/ schedule. Assigned roles/ tasks. Explanation provided of some of the local legislation concerning migrant workers. Overview given of key details from Pre- assessment meeting with Supplier. Informed of key risks to investigate. Advised to look for discrepancies during audit.

Day 2: Audit assessment

Opening meeting
Location: Supplier	AM
Attendees: Buyer A: BA1-7, NGO A: NGOA1-6, Supplier: S1-S6, Buyer B: BB1
Introduced audit team. Brief overview of schedule provided.
Supplier tour
Location: Supplier	AM
Attendees: Buyer A: All (except BA2 & BA6), NGOA: NGOA2-6, Supplier: S1, S2, Buyer B: BB1
Selection of workers for interviews/Document review
Location: Supplier	AM
Attendees: Buyer A: BA2, BA6, NGO A: NGOA1
The migrant workers employed at Supplier were recruited and hired through two main channels “Walk In” – Local, direct hiring of migrant workers already in the host country. These migrant workers already have a valid passport; visa and work permit on hand and can apply for a job by directly walking through the factory door. Recruited from overseas – These migrant workers have never been to the host country to work before. They need to go through recruitment agents in their home country to apply for a job at the factory.
20 workers selected from master list and attendance list Selection criteria: 10 x Recruited from overseas 10 x Walk In Position Start Date NB 3 additional workers selected and interviewed during audit
Comments: Audit findings highlighted that Date of Birth (DOB) could be a useful addition to selection criteria
Three parallel sessions
Location: Supplier			All day
Management Interviews/ Documents Review	Documents Review (Plus Interview with 1 x Supplier Translator S6)	Worker Interviews
Audit Team Attendees: Buyer A: BA1-4, BA7 NGO A: NGOA2 Buyer B: BB1 NB BA1 moved between sessions	Audit Team Attendees: Buyer A: BA1, BA6 NGO A: NGOA1, NGOA3 NB BA1 moved between sessions	Audit Team Attendees: Buyer A: BA1, BA5,BA6 NGO A: NGO4-6 NB BA1 moved between sessions NB BA6 moved to worker interviews after documents review
Supplier Attendees: S2-S5	Supplier Attendees: S6	Supplier Attendees: (Selected Workers) S7-22
Management interviews/Documents review
Referred to NGO A ‘Management Interview Guide’ document for guidance
Stage 1 Management Interviews (Group discussion) Key points covered: How Supplier recruits. Clarification of number of workers and Recruited from overseas/Walk In split. Recruited from overseas process. Documents sent to local government. Labour agency process and agreement. Visits to labour agency conducted. Recruitment and advertising. How Supplier specifies number/ type of workers required. Selection process. Fees (breakdown and who pays). Pay and terms. Contracts of Employment. Accommodation. Work Permits. Visas. Termination of Employment. Renewal of Employment. Transport from worker’s home country. Worker’s bank accounts.
Stage 2 Documents Review (Group discussion) Worker Files – 10 × Recruited from overseas, 10 x Walk In Checked if anything is missing. Application Form. Work Permit- checked date is valid. Visa- checked date is valid. Passport- checked date is valid and DOB. Checked all dates correlate. Induction documentation. Checked contract in two languages. Checked probation period. Checked if contract is detailed and provides all the required information Agency Licence (employees also need to be registered) Recruited from Overseas – Home Country Government Agreement (includes supplier and labour agency details) (Requested- given on Day 2) Employee bank books (Supplier in procession) Labour Agency contract
Documents review
Working hours and overtime. Annual Leave/ Holiday Request records. Wages. Policies – recruitment and migrant workers. Grievance Procedure.
Comments: Interview with Supplier Translator also took place
Worker interviews
Referred to NGO A Tool 4 ‘Conducting Interviews with Migrant Workers’ for guidance Main Topics covered: Recruitment and Hiring. Recruitment Fees and Expenses. Contracts of Employment. Document retention. Deposits. Wages and Wage Reductions. Compulsory or involuntary overtime. Freedom of movement and personal freedom. Workplace discipline. Threat of violence and intimidation. Worker Communication and Grievance Procedure. Termination of Employment.
Key points covered during interviews: Date of Birth (DOB). Start date. Family background. Literacy. Passport, visa and work permit arrangements. Home leave. Bank books – possession and access. Payment process. Orientation/ induction. Contracts- how many, when signed and where etc. Contract renewal. Transportation from home country. Medical test. Methods for sending money from country of employment to home country. Accommodation. Training. When the worker learnt to sew. Injuries. Personal Protective Equipment (PPE). Pregnancy and maternity leave. Workers asked if they had any questions.
Documents Review Passport, visa and work permit checked during interview. Worker’s file and holiday requests checked after interview.
Morning de-brief
Location: Supplier	PM
Attendees: Buyer A: BA1-7, NGO A: NGOA1-6
Discussion to highlight any issues requiring follow up during afternoon sessions: Anomalies identified. Risks/ Red flags identified. Documented any concerns. Key leads from management interviews identified. Key leads from worker interviews identified.
Wrap up with supplier
Location: Supplier	PM
Attendees: Buyer A: BA1-7, NGO A: NGOA1-6, Buyer B: BB1
Thanked for cooperation. Agenda for the following day provided.
Audit team de-brief
Location: Hotel	PM
Attendees: Buyer A: BA1-7, NGO A: NGOA1-6
Overview of day – recruitment, selection and hiring, any gaps in policies and procedures- each area discussed in turn. Cross-referenced findings. Red flags/key issues to follow up identified.

Day 3: Audit assessment

Two parallel sessions
Location: Supplier		AM
Management Interviews/Document Review	Worker Interviews
Audit Team Attendees Buyer A: BA1, BA2, BA4, BA5 NGO A: NGOA1-2 Buyer B: BB1 NB BA1 moved between sessions	Audit Team Attendees Buyer A: BA1, BA3, BA6, BA7 NGO A: NGOA3-6 NB BA1 moved between sessions
Supplier Attendees: S2-5	Supplier Attendees: (Selected Workers) S23-30
Management interviews
As per Day 1 and based upon feedback/discussion from previous day’s internal de brief
Worker Interviews
As per Day 1 and based upon feedback/discussion from previous day’s internal de brief
Post audit assessment meeting/Closing meeting preparation
Location: Hotel	PM
Attendees: Buyer A: BA1-7, NGO A: NGOA1-6
Brief overview of modern slavery provided. Audit triangulation- is there enough evidence to call a non-compliance or is it just a risk as issue could not be validated? Consolidation of findings – key risks and findings from management interviews, document reviews and worker interviews. Agreed on findings to be communicated to Supplier in closing meeting and split into themes to present in PowerPoint presentation. Areas of good practice identified. Gaps in policies/ processes identified. Key learning points from team discussed.

Day 4: Closing meeting

Closing meeting
Location: Supplier	AM
Attendees: Buyer A: BA1, BA2, BA4, BA7, NGO A: NGOA1-2, Supplier: S1-5, Buyer B: BB1
Brief overview of modern slavery legislation, due diligence and audit triangulation provided. Areas of good practice highlighted. Areas of concern/ risks/ findings (separated by theme) provided. Going forward- next steps / priorities discussed.

Day 4: Final reflections meeting

Buyer A reflections meeting
Location: Hotel	AM
Attendees: Buyer A Audit Team
Reflected on audit process in group discussion.