Canadian HR Reporter

CANADIAN HR REPORTER May 16, 2016 NEWS 21 shareholders are increasingly vigilant over the socio-economic footprint of many corporations, the award is an important con- tribution to ensure that the fight against slavery is perceived both as a human rights priority and a business imperative." e awards criteria highlight best practices in corporate com- mitment and reporting, perfor- mance measurement, business partner engagement, risk as- sessment and investigation and remediation. ese kinds of awards make sense because rewarding heroes is just as important as exposing villains, said Terry Fitzpatrick, di- rector of communications at Free the Slaves in Washington, D.C. "We want people who are breaking new ground and are trailblazing in this area and show- ing it isn't impossible" he said. "is kind of business recogni- tion program, from an indepen- dent authority... is really welcome because it's vetted — it isn't just a company's marketing but this is actually an outside entity that will look at who is being nominated and checking them out." Persistent practice Of course, it's unfortunate the awards even need to exist. "It's a misperception that slav- ery ever ended — it was outlawed but it was never really eradicated and it's always existed and per- sisted in some form in different places throughout the world," said Fitzpatrick. ere have been a couple of economic, global trends that have helped give slavery a bit of a global comeback, he said. "In many places, the population has grown faster than the econo- my and that leaves people vulner- able to exploitation and to having to migrate for work… Another trend that's happened is that a lot of manufacturing has moved from countries with strong labour laws that are well-enforced to coun- tries that have weaker labour laws that aren't enforced." So if a company moves its man- ufacturing to a place where slavery is endemic and labour inspection is non-existent, easily corruptible or just not stringent, that's when it can happen, said Fitzpatrick. "There could be two people doing the same job, say, in a gar- ment manufacturing company in Bangladesh and one is in slavery and other isn't. So it isn't neces- sarily the job, it's how you came to do that job and whether you can get out of that job and whether you're getting paid for that job that makes it slavery, and not just employment or exploitative employment." It's not just an issue that hap- pens internationally, he said. For example, the United States at- torneys office recently found out janitorial crews working at a big box store were part of a traffick- ing ring from the Ukraine, into Mexico and then the U.S. Modern day slaves often go un- noticed, said Villa. "ere is slavery hidden in the food, electronics and clothes we consume... there are more people trapped in modern day slavery today that at any given point in history." And global outsourcing makes it easier for employers to take ad- vantage of vulnerable workers, and harder for corporations to monitor and regulate the working conditions of those at the bottom of their supply chain, she said. One of the reasons slavery is an issue is it goes underreported far too often, said Sean Morris, feder- al human capital leader at Deloitte in Arlington, Vir. "It's in the shadows, particular- ly the labour side of it, so people don't realize it's there. On the global scale though, particularly in developing countries, it's part of economies and that's the prod- uct of large population increases over the last 50 years, migration issues — it's those people that are most vulnerable." But times are changing. Under Britain's Modern Slavery Act, companies operating in the U.K. with total revenue of 36 million pounds (C$66 million) or more must now disclose what they have done to ensure slave labour is not in their supply chains. More than 12,000 companies are impacted by the act, said Vil- la, "and there are clear potential brand and reputational damages in failing to comply." U.S. President Barack Obama signed a bill recently barring the import of goods produced by forced labour from entering the United States. And in Brazil, the ministry of labour is fining Bra- zilian companies for using slave labour. What should employers, HR be doing? To combat the scourge of slavery, there are several steps employers and HR in particular can take, ac- cording to the experts. Firstly, employers need to un- derstand, through the multiple layers of their supply chain, what's going on, said Morris. "In the global economy... you have to understand who you're doing business with, you have to understand who touches your supply chain. And that sounds easier said than done. Most em- ployers can definitely understand it down to probably the second layer. Where it becomes murkier is the layers underneath that." Secondly, they have to make sure employees are providing in- formation if they think something inappropriate is happening, so that's about putting your core val- ues out on the table, he said. "You have to educate them... because the headquarters could have the best technology in the world, but if the people that are truly at ground zero are not trained correctly on what to look for and when to report it and to feel empowered to report it — be- cause often there's a lot of fear that goes on here — then that's not go- ing to get fixed." It's also about encouraging em- ployees to have a social impact, said Morris, "actually living it as a social value that comes from, and that tone is set, from the very top of the organization. at one may sound a little touchy feely but that's what will make the most long and lasting impact in an or- ganization, that's where people will go the extra mile to make sure they understand the fourth and fifth level of a supply chain and that they put fear aside or cultural bias aside and raise their hand when something inappropriate is going on." As an example, it was reported recently an HR person at a food manufacturing plant in the U.K. noticing something odd with two employees and flagged the rele- vant authorities, said Mike Reed, an associate at Gowling WLG in London, U.K. It turned out their wages were going to a trafficker, so they were working in servitude. "(It's about) knowing that, within a country like the U.K., these sorts of things are happen- ing in various part of the country, and it's something that we can't simply ignore… and having a bit of training around that helps broaden that awareness within the organization." Companies need to push the issue from the top of the supply chain all the way down to the bot- tom, said Reed. "at includes the people who are involved in that sub-contract- ing and intermediate production steps and raw material and com- modity provisions." And in annual procurement of- ficer training, companies need to talk about this with the teams. "When they do site visits, they need to talk about looking at who's on the shop floor or who's in the mine, and not just on the qual- ity of product coming out of that mine or that factory, and under- stand the working conditions for those individuals there," he said. "Slavery is a little trickier than say fire safety or other kinds of things that say a Canadian or an American site inspector might just be able to eyeball because it's about how people came to do that job and whether they can leave, and not just whether there's adequate fire safety here or ade- quate meal breaks… it's a little bit trickier for the due diligence side." HR has an important role to play in making sure this is em- bedded within an organization in terms of policy, said Anna Fletch- er, director at Gowling WLG in London, U.K. "I see HR's role as being very much responsible for all policies and procedures to highlight the organization's approach to this. And that would involve HR work- ing in conjunction with your com- pliance teams, your procurement teams, risk teams and so on so it is completely embedded. But it's not just one department responsible for one section of this, it's a much more joined-up approach so we can ensure as well that if we're going to encourage people to re- port concerns, there's a reporting mechanism in place." U.K. employers are setting up sub-teams or sub-committees with a representative from each of the key parts of the business co-ordinating the approach, so that stops it being siloed, she said. Training is also important, so the people who need to know about this really know the ins and outs of the legislation. "at's not necessarily some- thing that every employee needs to be aware of but there will need to be a wider awareness within the business and, again, it would seem to be me this is about people, and therefore that dissemination of in- formation would fall to HR to deal with," said Fletcher. HR has important role to play EMPLOYERS < pg. 1 Credit: Surapan Boonthanom (Reuters) Police officers stand near a fishing boat during an inspection in south Thailand in December. Thailand has come under fire from rights groups over allegations of trafficking, abuse and exploitation on its fishing boats.

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