Today marks Anti-Slavery Day 2016, a day introduced in 2010 by Anthony Steen CBE, then MP for Totnes through a Private Members Bill. Since then, it has grown significantly with an increasing number of awareness raising events taking place each year. This year, the day is being complemented by a dedicated week (17th – 23rd October is Anti-Slavery Week). Unseen, a charity committed to helping victims and survivors of modern slavery have coined a fun social media challenge called #letsnailit. ‘Let’s Nail It’ asks everyone (men and women) to paint their nails in bright colours to highlight that modern slavery is happening - right here - right now.
A dedicated day and week are all positive gestures, but if we were to fast-forward five or ten years, would 2016 be considered a turning point in the UK’s fight to eradicate modern day slavery?
Only time will tell; however, for now, there are at least four reasons why it looks promising and may be the best chance of being the catalytic year that is needed to deepen awareness of the issue, take collective action to prevent, address and prosecute (where relevant), and ultimately, put a stop to such abusive practices.
1. Premier support: For the first time in history, there is a premier driving the issue forward, evidenced through both words and a commitment to action. Through speeches, op-eds and interview responses, Prime Minister Theresa May has routinely outlined her mission to address modern slavery, both in the UK and abroad. Soon after accepting her position, she vowed to make it her mission to rid the world of what she referred to as a ‘barbaric evil’, writing an op-ed in The Telegraph entitled, “My Government will lead the way in defeating modern slavery” (30th July 2016). Such commitment has been backed up by action, through the announcement of a cross-departmental Modern Slavery Task Force (which will coordinate the UK Government’s efforts to tackle slavery) and the establishment of a dedicated International Modern Slavery Fund (which will have £33m earmarked for pilot projects and priority areas in key sourcing countries). Keen to ensure gaps are not missed, a review of the Modern Slavery Act has already been commissioned and completed. Not bad given it’s only one year since it came into force.
However, while ‘premier support’ is all well and good, such leadership merely indicates the (intended) direction of travel. The UK Government needs to demonstrate leadership through collective and consistent action. So far, simple yet effective practical ways for UK Government agencies to address modern slavery, such as changing their respective procurement practices has been slow. The recent report by the Independent Anti-Slavery Commissioner, Kevin Hyland OBE, outlines this as a priority area for 2016/17. In order for us as UK citizens/residents to believe the government is really committed to leading the world in combatting modern day slavery, we will need to see government departments (both national and local) changing their own behaviours and actions. It’s a quick win that will have significant positive ripple effects; effectively, forcing government suppliers to take their obligations within s54 Modern Slavery Act seriously, and demonstrating to other governments around the world what real government commitment looks like.
2. Independent oversight: While the Independent Anti-Slavery Commissioner (IASC) has been in post since 2015, 2015 was the first year - the scene setter - for both Kevin Hyland OBE to establish his team but also stakeholders addressing modern slavery to see how he will approach the role. His strategic plan outlined five priority areas, rightly placing victim identification and care first. This was followed by the need for improved law enforcement and criminal justice (2), promoting partnerships (3), private sector engagement (4) and international collaboration (5). His first annual report provides a comprehensive summary of the various activities that he has undertaken from 2015-2016. While the breadth and depth of his interventions is to be commended, what is more impressive is how the report calls on certain actors to step up their game, for example, the police.
The independent nature of this role is critical to ensure progress in the field. By being independent, the Commissioner has the power to call out underperformance (which he does), make strong recommendations (which he does) and remind us all of the end goal - the eradication of modern slavery (which he does). 2016 anchors the role of the IASC in the unveiling of his first annual progress report, dedicated website launched today (http://www.antislaverycommissioner.co.uk/) and an increasing number of media comments and appearances made during the year, making the role and work of the IASC seep into a wider public consciousness, which leads me to point three.
3. Media coverage: 2016 has seen a sharp increase in the variety of media outlets (both old and social) raising awareness of forced labour, human trafficking and modern slavery. Many news agencies and papers have addressed it head-on, covering the risks, highlighting prosecutions but also giving space to the human pain and documenting the impacts and feelings faced by victims and survivors. For some, it’s become a focussed feature of their current offering. In addition to increasing the number of special investigations into industries tainted with slavery, the Guardian online has a dedicated webpage entitled ‘modern day slavery in focus’ where you can access and read all of its articles for free. However, Coronation Street’s production team’s decision early on in the year to tackled modern slavery and ITV’s ensuing Advice on the Act, the role of the Commissioner, and notification of the free Modern Slavery Helpline (0800 0121 700) highlights how the issues are slowly making inroads into a broader public consciousness. By showing that slavery can exist right here in the UK, Coronation Street has contextualised what is often hard to imagine (and for some, accept) in a UK setting, and in doing so, has informed the British public in a way written media formats cannot.
4. Private sector acknowledgement: While it is true that the majority of companies have not fully embraced the spirit of s54 which requires companies with an annual turnover greater than £36 million to report on the steps they are taking to address and eradicate modern slavery in their business and supply chain, some have been candid about what they have found during their own investigations. In February 2016, Nestlé openly acknowledged that they had found forced labour in its supply chains in Thailand. While some point to the fact that it was hard to deny as it was ‘accepted knowledge’ in the industry, it cannot be overlooked that such public acknowledgement by a large global brand has demystified the idea of ‘coming clean’ for companies that become aware of similar incidences in their business and/or supply chain. Here’s hoping that many others will follow suit in 2017; acknowledgment must be the first step if a company is to take its obligations under s54 seriously.
By Désirée Abrahams
#antislaveryday #modernslavery #humantrafficking
When we were asked to partner with CIMA and AIPCA to develop ‘Business and Human Rights: Evolution and Acceptance’ - guidance on business and human rights for management accountants, we were thrilled.
With an eye on stability, growth and profitability of a firm, management accountants play an instrumental role in a company and have the potential to be one of the ‘game changers’ within it, when it comes to integrating business and human rights.
Why do I say that? Well, if they can get human rights and what it means to embed it within their daily activities, surely there will be positive ripple effects throughout the organisation?
Management accountants are the financial stewards of any organisation. They manage risk, reduce operating and production costs, and advise on the financial implications and consequences of all business decisions, among other things. They are always strategic and forward-looking in outlook. These are some of the essential core skills required when assessing the impact of a business, financial or otherwise.
If they are able to understand the human cost of doing business - interpret and account for it as a financial cost – internalise it into the cost of doing business – and communicate such information to the management board and other key teams, surely such improved awareness will enable businesses to understand key areas of vulnerability (viewed from both a human and business perspective) and put in place effective measures to address any identified problems?
I’m sure you think that all sounds a bit lofty; easier said than done...!
Breaking it down into manageable actions, let’s consider what embedding human rights means for a management accountant on a daily basis.
Take insurance policies; something that all financial accountants will take out to protect the company from all manner of eventualities.
Going forward, and with a human rights lens applied, an accountant could look out for any clauses in contracts that may intersect with any of the company’s identified salient human rights. If the wording is vague, he or she could request that specific clauses safeguarding the organisation’s activities, actions or relationships with respect to human rights are included. Strengthening wording throughout the contract to ensure that the business is covered regarding any potential violation of human rights, is another way to integrate human rights concerns within an insurance policy.
Then there is the allocation of funding, a key aspect of an accountant’s role. With heightened awareness of how the business may impact human rights, an accountant would be able to understand budget requests for important activities such as stakeholder engagement, human rights impact assessments or remediation programmes, to name a few. However, more importantly, they will be able to keep track of expenditure with greater knowledge of the intended purpose and be able to discuss solutions with relevant teams, ensuring that any agreed approaches are not only cost-effective but also adequately address the needs of the affected stakeholders.
These are just two examples; the guidance offers 10 key steps (and even more sub-steps!) for management accountants to consider. However, in order for integration of human rights within a business to be effectively diffused, this will require good collaborative working within and between business functions. Management accountants will be expected to work with colleagues from other departments, such as, Corporate Reporting / Corporate Responsibility or Human Resources etc.
For example, management accountants and the Corporate Reporting team could jointly develop human rights-related Key Performance Indicators and agree on the company’s management-reporting system addressing non-financial issues, such as human rights. This would be prudent in light of the forthcoming EU Directive on the disclosure of non-financial and diversity information and the existing requirements under the Modern Slavery Act 2015 and Transparency in Supply Chains Act.
In summary, human rights is a cross-cutting issue that manifests in a many guises within a company and intersects with various business functions, albeit in different ways; management accountants are not immune.
What needs to happen now is an ‘infusion of human rights considerations’ within their role. This means, a reconsideration of how each activity may adversely impact the human rights of the company’s affected stakeholders, and following such reconsideration, adapting internal processes and changing behaviours, accordingly.
By Désirée Abrahams, written in her capacity as Head of Insight and Capacity at Global Compact Network UK. She is co-author of Business and Human Rights: Evolution and Acceptance
I haven’t written a blog for ages. It’s mostly down to me being a lot busier since becoming a Mum; however, last week I saw something that got my juices flowing, and just had to find time to put this down and share it. Last week, during my stroll, I saw this.
I couldn’t believe my eyes. Right in front of me was a boy (I’m guessing around 9 years old), with his Mum and presumably sibling (in the pram) walking down the road, brandishing a toy gun, which actually looks like an imitation firearm from afar. I was horrified.
Horrified - that a mother would allow her son to have it and play with it. Horrified - that she would let him take it out in public. And lastly, and probably most of all, horrified that they still exist!
I remember growing up during the 80s and hearing debates about toy guns and the bad/ long-lasting effect it had on children. I thought the debates were had - won by the ‘anti’ lobby - and it remained a thing of the past. In the 21st century, what does a child need a toy gun for? Aren’t there enough things for children to play with these days? Surely there is more stuff out there than ever before, as designers and manufacturers find ways to invent and reinvent new things?
This got me thinking and I went on a fact-finding mission. How many toy guns could I see for sale in the shops on the high street? Which shops were they sold in? And how much did they sell for? From my brief sample in an area that will remain undisclosed, you can purchase toy guns for as little as a £1, and they are everywhere. And I’m not just talking about the water-gun types in colourful colours; most, like the one in the photo, look like miniature versions of real guns.
On the legal front, the Violent Crime Reduction Act 2006 in the UK restricts the manufacture, importation and sale of such products. Within the same piece of legislation, children under 18 are banned from purchasing what’s considered non-realistic imitation guns. So we can only hope that the boy in the photo wasn’t sold it in a shop, in the UK.
Which begs the question of ‘responsibility’? Who has the lion share of responsibility parents/carers or the companies that manufacture, import, advertise and sell such products?
While most would agree that parents or carers should ultimately have the lion’s share of responsibility, photos like this one suggest that maybe it’s time some companies really got to grips with corporate responsibility. I’m talking about genuine corporate responsibility. The type of actions that society would consider as the right thing to do. In essence, business decisions and actions that are driven by concepts such as ‘do no harm’ as advanced in the UN Guiding Principles and Business Human Rights, or better still, for those companies whose products or services affect children, business practice that is guided by the ‘best interests of the child’ principle.
I’ve always thought that the Children’s Rights and Business Principles (CRBP) was a great concept. A set of guiding principles laying down the foundations for what companies should do to ensure their products, services, operations and business relationships do not adversely impact the rights of children anywhere! Yes, anywhere! The CRBP highlights a multitude of children that may be adversely impacted by business activities, mostly unintentionally but sometimes, sadly, intentionally. The obvious ones are the children who supplement their parents' incomes by going out to work as child labourers, whether by choice or through coercion. However, the CRBP makes the case that companies should consider how the working lives of their employees or contractors may be negatively impacting home life based on the stresses associated with excessive working hours, poor working conditions, low pay, or all three. It considers how companies can adversely impact the lives of children they don't even know; for example, those living near a factory or manufacturing plant that may be potentially contaminating water that the local children may drink or bathe in. And of course there are the children like the boy I saw; the children that are consumers and those that will be future-consumers.
After last week’s observation, I realised the value of the CRBP even more, and believe that companies need to crank up efforts to integrate a child rights perspective into their business decisions, and assess their operations and relationships accordingly. At a minimum, those that develop products and services targeted at children should consider how it potentially impacts children in a variety of ways. For example, given that children are a vulnerable group in society, subjected to extra protections and safeguards, there is merit in assessing the potential adverse impact on a child’s psychological health arising from interaction with a product or service, as well as making sure it will not harm them physically. The toy gun in the photo, which could pass for an imitation firearm, presumably passed numerous legal, technical and product safety tests at the EU level; however, surely the most damaging aspect to any children playing with a toy looking so realistic is the potential negative and long-lasting impacts it will have on their mental health?
For companies, it’s all too easy to say that they respond to consumer demands. In my view, companies that manufacturer and/or sell stuff for children have a real opportunity to assert their corporate responsibility and actually be 'responsible'. Companies can say: "No; we won’t manufacturer or sell X, Y or Z because we believe that it would not be in the best interests of the child."
And if they were to do that, now that would be true corporate responsibility!
An invitation from the American University of Beirut's Olayan School of Business to speak at a regional CSR conference earlier this month provided an opportunity to assess how far the business and human rights agenda has penetrated the Middle East and North Africa. It was a good reality check.
In two days of lively discussion about responsible business in the region, human rights were hardly mentioned. Indeed, if I had not raised the subject, it might not have featured at all. That is not to say that businesses in the region are oblivious of human rights issues, or at least of economic rights. It is just that these issues are seen through a developmental, rather than a human rights, lens. There were some excellent stories about company activities aimed at improving access to education and health, empowering women, creating jobs and fighting poverty. Many businesses also have mechanisms in place to fight corruption, at least in their own business dealings.
But the lack of a human rights focus means that these challenges tended to be viewed from the angle of the business, rather than the people affected. Nor was there much appetite to discuss political rights, despite the controversy over the role of communications companies in last year's unrest in Egypt, or the role of businesses in conflict-affected, or post-conflict, areas. Apart from a thought-provoking keynote speech by the Lebanese Minister of Economy and Trade, there was no evidence of government engagement during the discussions.
The programme was thoughtfully put together and excellently organized by the Director of the University's CSR Initiative, Professor Dima Jamali. As more governments and companies develop policies and processes to apply the UN Guiding Principles on Business and Human Rights, it is probably only a matter of time before human rights assume a more prominent place in discussions in the region about responsible business practices. The issue is already on the University's agenda, as is the need for greater government engagement alongside business and civil society.
Last month, the chief executive of Barclays, Bob Diamond, gave the inaugural BBC Today Business Lecture. Banks, he said, must be better citizens if they are to win back the public's trust. They have to focus on the interests of the customers, clients and communities that they serve. Banks, he explained, have a vital role to play in creating jobs and economic growth. But they needed to restore public trust: no taxpayer money should ever again be put at risk to rescue a failed or failing bank.
Also last month, we learned that Barclays have teamed up with Credit Suisse, UBS and UniCredit, with the support of the University of Zurich, to form the Thun Group and develop a practical application guide to operationalising the UN Guiding Principles on human rights and business in universal banks.
At the same time a Strategic Review of the Equator Principles (EP) is under way and is addressing, among other things, the scope of the Principles, climate change, reporting and transparency and proposals on how to integrate the new IFC Performance Standards language on social risks, stakeholder engagement and human rights into EP III.
The potential for banks to have a positive or negative impact on human rights has long been recognised. But the current global economic downturn, with its huge impact on the economic rights of millions of people, and the fact that the banking sector has been seen by many to be largely responsible for triggering it, has broadened the debate and given corporate responsibility, when applied to banks, a whole new meaning.
Do the tools exist to ensure that Bob Diamond's laudable aspirations can be realised? The Equator Principles, in their current form, are clearly not designed to prevent banks from having major adverse impacts on human rights at a global level by engaging in irresponsible operations in financial markets. While the UN Guiding Principles make it clear that businesses should avoid causing or contributing to adverse human rights impacts through their own activities, developing a due diligence approach that covers the whole range of ways in which banks impact on human rights, not to mention the provision of remediation to those affected, is a mind-boggling challenge. So we wish the Thun Group well!
As for States, they have to decide to what extent they can rely on banks to address these issues themselves, through codes of conduct and such like, and to what extent new or amended regulation will be required. It seems inevitable that action will be needed on both fronts. Bob Diamond said in his speech that strong banks wanted strong regulation. However, in the UK at least, the response of much of the banking sector to the recommendations in the Independent Commission on Banking report suggests that there is still some way to go before the sector, as a whole, is ready to face up fully to the challenge.
By Graham Minter