A FTSE250 Company Secretary writes...
“What due diligence process are you adopting to ensure that the requirements are met under the Modern Slavery Act 2015 and who are the key stakeholders in your organisation that will be involved in implementing/taking action on this?”
We have updated the Supplier Code of Conduct, the code of business conduct and the training associated with the code of conduct.
In terms of due diligence, we have also discussed with the procurement director, the risk areas in the business. The conclusion is that the telecom industry in which we operate is a low risk area in relation to potential breaches of the Modern Slavery Act. Nevertheless, we developed and sent a Modern Slavery questionnaire to the top 20 suppliers as well as suppliers in more sensitive areas (hardware manufacturers, merchandise supplier, HR recruitment services and the two largest India based suppliers). These represent 35% of our annual spend. Will analyse once returned and follow up as relevant.
We do not have a formal due diligence process. Each division is responsible for ensuring compliance, with oversight from the Group. The key stakeholders are each divisional Managing Director, the Group Chief Executive, and the Group General Counsel