Modern slavery is not a problem that can be solved in the abstract. You have to get to the real humans behind all the risk assessments, slavery statements, and policy updates. Collaborating down chains of supply is a way most organisation’s can take action to help those at risk or in need, and contribute towards ending modern slavery.
One simple way to start engaging and increasing transparency up the tiers of your supply chain is by utilising a Self/Supplier-Assessment Questionnaire (SAQ). SAQs are helpful for filling information gaps in your supply chain and for fostering collaboration with suppliers to address human rights risks. They can also help detect areas of concern that may require further investigation and due diligence.
Before we share our top tips for using SAQs as a tool to mitigate modern slavery risk, we want to make it clear that SAQs are just one tool in your kit to engage with your suppliers and to gather and share information. They should not be the only means used to engage with suppliers and not be relied on as a single measure of a supplier’s modern slavery compliance risk. It’s also critical for SAQs to be effective, they should evolve and adapt along with your organisation’s counter-slavery response. Think of this process as an iterative journey.
Now let’s share our top tips on how to use modern slavery SAQs effectively, how to get suppliers to respond, and how to actually use the responses once you get them back.
Our top tips on how to use modern slavery SAQs effectively
- Use your SAQs to hone in on high-risk supplier categories and ask them very specific questions that matter to your counter-slavery response. For example, ask specific questions about the composition of their workforce, the extent of their own controls, and what they know about their supply chain. Also enquire about how open and willing they are to collaborate further on these challenges.
- Collect tier-2 supplier data from your tier-1 suppliers. Have them provide as much detail as possible on where they source from. Have them identify industry and sector for each supplier using the UN Standard Products and Services Code or the Global Industry Classification Standard (GICS) to add detail to your risk assessment methods.
- Test whether your supplier is willing to back the information they have provided in the SAQ with evidence. For example, if you’ve asked a standard question around wages and legal entitlements to pay, you could ask if they’d be willing to share evidence of their practices.
How to get your suppliers to respond to SAQs?
The other thing you need to think about to use modern slavery SAQs effectively is participation. We all know, getting suppliers to respond to your SAQs is very hard work, especially if you are not a giant multinational with a large amount of influence over your suppliers.
So, how do you optimise responses to your SAQS and encourage accuracy?
- Keep your next-gen SAQs short and targeted.
- If you established a personal contact – pick up the phone before you send a new SAQ request. By establishing a relationship with a supplier, you are much more likely to elicit participation.
- If your SAQ is online, review and test the user interface before sending – there is nothing worse than a clunky or poorly thought through online SAQ. For example, users may want to add comments under a yes/no question but cannot, or they may feel compelled to answer incorrectly because the answers were too limited.
How to score and use SAQ responses
So often we see organisations sending out SAQs, getting responses back, but then not knowing what to do next. It’s important to put the good data you are collecting to use by scoring and then applying your SAQ results into your modern slavery risk assessment methodology. Ideally, you want an automated system, but most organisations are still manually scoring their SAQs and then updating each supplier’s risk score accordingly. Either way, simplicity is key. We have a few suggestions below for keeping your SAQs simple:
- Ask closed questions where appropriate (Yes/No) – noting that binary questions are not appropriate for all types of issues and there should always be an option to provide comments.
- Where a human is required to analyse and score a response, make sure to create instructions for how to interpret responses and what to look for.
- Also think about supporting your SAQ process with contractual provisions. If a supplier agreed to respond to SAQs in their contract terms, they are more likely to participate.
- For scoring your SAQs, you can even use a simple 3-point score for each – something like: high-risk, neutral, low risk.
- Sum up each supplier’s overall score and use that to adjust their risk level in your supplier management system.
- Feed this info into the assurance actions you require from your supplier. For example, you might have a system where only high-risk suppliers are required to undergo audits, or vendor training.
There you have our top tips for how to use modern slavery SAQs effectively. As we mentioned, they are a tool you can use to gather information from your suppliers, but they should not be the only means you use to engage with suppliers. SAQs have plenty of limitations, but when done well, they are an excellent first step towards understanding human rights risks up the many-tiers of your supply chain.
This information has been adapted from our recent webinar with Baker McKenzie – ‘Second Slavery Statements: Making & Showing Progress,’ you can view the full webinar here.
For more detailed and technical guidance and advice on our human rights services or specifically modern slavery reporting, SAQs, risk assessments, and what to do next, contact our Principal for Human Rights, Brian Kraft at email@example.com or give us a call 03 7035 1740.
As an Australian business founded in 2010, over the last decade we’ve helped hundreds of clients play a part in the transition to a more sustainable future and have assessed nearly 5000 suppliers for modern slavery risk.
Michaela is highly experienced in the fields of International Environmental and Climate Change Law and works on both environmental and human rights projects.