What do I need to know about Anti-Slavery and Anti-Human Trafficking Laws and Regulations?
If you have received a request from a customer to complete the Slavery and Trafficking Risk Template (STRT), there is no reason to be alarmed. It is a due diligence activity your customer must perform, and is in no way an accusation of your company’s conduct.
Why is my customer asking for this information?
You have been asked to complete an STRT because your customer is subject to and/or impacted by one or several slavery and human trafficking laws and regulations, such as the Trade Facilitation and Trade Enforcement Act (TFTEA), UK Modern Slavery Act (Section 54 - Transparency in Supply Chains), Australia Modern Slavery Act and US Federal Acquisition Regulation final rule on Combating Trafficking in Persons (52.222-50). Your customer is exercising due diligence over its supply chain and needs your participation to meet its due diligence obligations.
Do I really need to do this?
Refusal to provide the requested information to your client may affect its ability to access the US market, retain contracts with large institutional buyers and corporations, and maintain the confidence of its shareholders and the communities in which it operates. Refusal to provide the requested information to your customer can be grounds for the termination of business activity.
What do I need to do?
You need to provide your customer a complete Slavery and Trafficking Risk Template (STRT), along with supporting documentation. The STRT should be completed by someone within your organization who has a good understanding of how your organization manages slavery and human trafficking risks. Since an organization’s response often spans multiple departments, this individual may require input from multiple groups, such as human resources, legal, procurement, corporate responsibility and corporate affairs.
What is the real focus of this?
The focus of your customer’s inquiry is to assess your organization’s exposure to slavery and human trafficking risk and - where such risk exists - how well your organization is managing this risk. Your customer will use this data to inform its onward due diligence actions. The STRT was designed by the Social Responsibility Alliance to launch and accelerate a journey of continuous improvement between businesses on slavery and human trafficking. The STRT is a free, standard template that’s available for download at www.sraglobal.org.
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