Learn about your organization’s possible connections to modern slavery and human trafficking.
Businesses in the financial sector can involuntarily enable or facilitate modern slavery and human trafficking – through their own operations, or more likely through their business relationships.
Understanding these connections is essential to tackle this problem. This tool will help you find out:
Most people take about 10 minutes to complete this. In that time 60 people will have needed to be removed to modern slavery and human trafficking in order to meet the United Nations Sustainable Development Goals Target 8.7 – which aims to end modern slavery by 2030.
LET’S GET STARTEDFirst, let’s identify ‘heightened’ risks of modern slavery and human trafficking in your own operations or business relationships.
This is sometimes called identifying the ‘scale’ of these risks.
Does your business operate in locations or contexts where the risks of modern slavery and human trafficking are especially high? Or do other businesses associated or linked to yours operate in such locations?
For example: isolated worksites, prisons, refugee and displaced-persons camps, or in communities affected by conflict or political violence?
Is your business associated with high-risk products or service categories?
For example: high-risk business lines can include cantinas, ship salvage, artisanal mining, domestic service agencies, manufacture of branded non-resale goods or specific commodities.
Is your business linked to high-risk entities? Have you examined sanctions lists, government reporting registers, civil society research publications or media reports?
Are there high-risk labour or recruitment arrangements in your business operations, or in the operations of businesses with which you have a relationship?
For example, they might rely heavily on foreign subsidiary or third-party labour brokers, or migrant or refugee labour. They might not provide employment contracts in workers’ native language, or wage inflation may not keep pace with general inflation.
Does your business operate in a market or value-chain with high-risk factors?
For example: where purchasing power is concentrated in the hands of a small number of businesses, where the supply-chain is highly fragmented, or where market demand for low-skill labour is volatile.
If you answered ‘Yes’ or ‘It’s possible’ to any of these questions, you may be facing a situation of high-scale risk. Whatever your answers, though, the next step is to consider three other factors: scope, remediability and likelihood.
The three types of factors to consider are:
The higher the concern in each case, the greater priority these risks should be given.
Your answers to the questions of scope, remediability and likelihood will help you map the most ‘salient’ risks. They give you a starting point.
But when you do identify risks to people connected to your business, how are you expected to respond?
That depends on the nature of your connection. Let’s explore that.
There are three types of connections between businesses and people at risk of modern slavery or human trafficking:
Under the international standards set out by the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, different responses from business are expected in each case.
Let’s start with causation. Are the activities (the things you do) or omissions (the things you don’t do) of your business sufficient on their own to result in modern slavery and human trafficking?
For example: is it possible that janitorial, landscaping or cleaning employees in your own business could be working under conditions that amount to forced labour?
Or, for those companies that provide credit, is it possible that the repayment terms could amount to debt bondage?
In that case, your business may ‘cause’ modern slavery or human trafficking. You should:
a) cease the activities that produce this result; and
b) provide effective remedy for any harm that has been caused.
Now let’s look at contribution. Do your activities combine with those of a third party or parties to cause modern slavery and human trafficking?
Do your business’ activities combine with those of another business in a way that may generate modern slavery or forced labour risks?
For example your business might:
Is your business encouraging or motivating another entity to cause modern slavery and human trafficking?
For example, in a business relationship, are you providing financing for another entity that is known to use forced labour, or rely on it in its supply chains, without taking effective measures to address these practices?
Examples might include:
In that case, your business may ‘contribute’ to modern slavery or human trafficking. You should:
a) cease the activities that produce this result,
b) use or increase your leverage with the other party or parties involved to get them to do the same, and
c) contribute to effective remedy for any harm that has been caused, proportionate to your contribution to the harm.
The financial sector touches nearly all industries and a broad array of businesses. Are the operations, products or services of your business linked to modern slavery and human trafficking in some other way?
Examples could include:
If your business’ operations, products or services are linked to modern slavery and human trafficking harms, you should:
a) use or increase your leverage with the other parties involved to get them to prevent and mitigate these risks; and
b) consider how you can enable the provision of an effective remedy, including through taking system-level action.
Depending on whether your business is causing, contributing to or linked to modern slavery and human trafficking risks, it will face different response expectations. This often requires building and using leverage, and providing and enabling remedy.
You may need to seek specialist guidance to meet these expectations.
FAST offers a number of other resources and initiatives that may be useful:
That’s a start! Working together, actors in the financial sector can help to end modern slavery and human trafficking.