How does FRDM help me write my Annual Statement? FRDM works with clients in many countries that require annual or periodic statements surrounding supply chain transparency. The specifics differ from country to country, but the general goal is the same: Increase transparency in the supply chain in order to see, measure and ultimately eliminate modern slavery from the planet. This article will give you some tips and tricks on how to use FRDM to make writing your annual statement a little easier.
AUSTRALIA MODERN SLAVERY ACT
CANADA MODERN SLAVERY ACT
CORPORATE SUSTAINABILITY DUE DILIGENCE DIRECTIVE
FRENCH DUTY OF VIGILANCE ACT
GERMAN SUPPLY CHAIN ACT
UYGHUR FORCED LABOR PREVENTION ACT
UK MODERN SLAVERY ACT
CUSTOMS-TRADE PARTNERSHIP AGAINST TERRORISM (CTPAT)
If these regulations have a reporting requirement, they’re generally light on the details surrounding this reporting. Most of the legislation is relatively new with the exception of Australia that has had a Modern Slavery Act since 2018. No matter the country you’re in, if you want to get a sense of what your Modern Slavery Statement might look like, Australia has made it a requirement that the statements required in its legislation is public. Check out the Australian Modern Slavery Statement Register to get some inspiration.
Understand the Requirements
Most reporting requirements are similar. While its important for you to read and understand the nuances of the individual legislation that you are subject to, if you hit these key points you’ll most likely be able to cater your reporting to any individual legislative requirement:
- Mapping your structure, activities, and supply chains;
- Documenting policies and due diligence processes;
- Assessing your human rights risks;
- Accounting of your remediation efforts;
- Training;
- Assessment of effectiveness.
Define Your Scope
It is unrealistic to map and mitigate human rights violations across your entire supply chain. Governments know that and intentionally leave the scope of the efforts required to comply with the legislation vague. It is up to you to define your scope. Your supply chain is massive and its not realistic to mitigate risk across its entire breadth, especially not in your first or second year of reporting. Its important to define clear and realistic goals. Here’s an example of a game plan for both risk mitigation and the subsequent reporting around that:
- Year One:
- Map our Tier 1, Tier 2 and Tier 3 suppliers.
- Analyze the risk of our Tier 1 suppliers.
- Rank our Tier 1 suppliers by our spend with those suppliers and their risk level.
- Focus on the high risk suppliers responsible for our highest spend (and thus highest risk exposure).
- Send these high risk suppliers their Risk Analysis and Upstream Supplier Risks.
- Schedule Company wide Modern Slavery Awareness Training.
- Work with these suppliers to create a mitigation plan.
- Year Two:
- Map to Tier 4 and Tier 5 suppliers.
- Refine analysis on Tier 1 suppliers (update industry or product information, add additional data)
- Begin Tier 2 analysis.
- Expand Tier 1 supplier focus to lower spend suppliers.
- Increase mitigation requirements based on feedback from Year 1 supplier collaboration.
- Introduce Tier 1 supplier driven mitigation process with Tier 2 suppliers.
- Schedule Company wide Modern Slavery Awareness Training and invite Tier 1 Suppliers.
- Assess Year 1 mitigation efforts. Highlight successes and improvement opportunities.
This plan tackles all six common requirements outlined above while also maintaining a feasible scope.
1. Mapping your structures, activities and supply chain
FRDM can map your supply chain, and help you understand where your relationships lie upstream without the need to ever contact your suppliers. We can tell you where your suppliers do business, with what companies, and operating out of which countries.
This gives you a far greater understanding of your supply chain, in a far shorter time than you could accomplish with questionnaires. In addition, the very act of setting up your FRDM account will fulfill most of the stipulations of many of the bills currently in place today.
We can show you things like risk and country distribution of your tier 1 suppliers, breakdown your industry stratification, or use our Trading Partners module to show maps of sub-suppliers being monitored.
FRDM uses third party data aggregators to create a data-driven, evidence backed mapping of your supply chain. This isn’t speculation, it uses actual shipping manifests, customs documents and other sources to track who your suppliers source from, who those sub-suppliers source from and so on down to the 8th tier. It’s rare that companies are engaged directly with sanctioned or high-sanction risk entities, but almost all Modern Slavery is explicit that companies are responsible not just for their direct relationships but for the trading relationships upstream. As such, it’s imperative to have visibility deep into your procurement pathways.
2. Documenting Policies and Due Diligence
FRDM helps assess your company’s policies and procedures as well as federating the policies and procedures of all suppliers. We work with companies all over the world, advising them on best practices.
FRDM works with hundreds of companies within dozens of legal jurisdictions. While we don’t offer direct legal compliance advice, we’re happy to provide context based on our experience to help your team shape their own internal policies. Our in-app assessment tool will help you determine where you stand. In addition, modules within FRDM can help provide frameworks for internal policies:
FRDM tracks Human Rights Media Alerts based on the countries, industries, products and suppliers uploaded into our system. It also provides you with the ability to share and track responses to these alerts:
Creating a set cadence for monitoring, responding to and tracking these alerts could be a viable policy for S211 reporting.
FRDM’s Product Genomes provide incredible detail into where raw materials are likely sourced for products. Use this information to build out processes for vetting new suppliers or help existing suppliers find less risky sourcing opportunities. Reach out to support to find out more ways to utilize this data!
3. Assessing your Risk
Reporting must include information about a company's risk analysis of the entire supply chain and the steps it has taken to assess and manage that risk. FRDM will take the supplier information provided and automatically analyze risk based on a multitude of leading human rights reporting sources.
FRDM can help you risk rank so you know where your highest exposure is. You can then create a plan for what your relationship looks like with these suppliers moving forward.
Now that you know where the risk is, you know where to start!
This may include finding alternative sources for the necessary products, or having a conversation with the suppliers where they provide mitigating documentation showing their commitment to rooting out human rights abuses in their own supply chain. You can then collect that documentation right in the platform:
FRDM can also provide Sanction Risk Warnings so you can proactively try to avoid supply chain interruptions. Tracking the sharing of these risk factors across your supply chain helps stabilize your procurement pathways and provides insight for sub-suppliers to root out human rights risks in their own supply chains.
In addition to the sorting and filtering in the platform, the FRDM support team can also help you build custom data extracts so that you can slice and dice the data we provide in anyway you see fit. Reach out to support@frdm.co to learn more about custom reporting!
4. Accounting of your Remediation Efforts
Once risk is determined FRDM offers multiple mitigation tools to address risk. This means showing the actions, uploading audits and custom action plans, as well as monitoring media alerts and resolving those alerts.
Your actions are tracked in aggregate and individually. You can use our standard visuals or, as with everything else in FRDM, your FRDM support team can help you build custom data extracts so you can display your data exactly how you want it.
5. Charitable Causes
Some of the bills we’ve seen have opportunities for you to talk about other avenues you are mitigating the affects of modern slavery in the world. In these cases, any corporate donations around human rights causes is most likely reportable in this section. For FRDM’s part, we donate a portion of all of our contracts to organizations and projects protecting children from slavery. This can (and should) be part of your reporting for this requirement.
6. Training provided to employees
FRDM has both synchronous and asynchronous training opportunities for our clients. Here are just a few of the options available:
- Slavery Footprint - Build finding out your personal slavery footprint into your team’s human rights awareness training.
- Modern Slavery Training - Free for FRDM customers, take our Modern Slavery Training courses.
- Workshops - Collaborate with the FRDM support team to build internal, or co-hosted, modern slavery awareness workshops for your team.
- Keynotes - In addition to being our CEO and Founder, Justin Dillon, is a writer, activist and speaker.
As a company founded on the mission to stop forced labour, we can and will help your organization understand the true impact of your due diligence and improve.
7. Assessment of effectiveness.
FRDM tracks your and your supplier’s risk and mitigation efforts over time. Both within the platform itself and via the custom reporting you’ll build out with your support team, you can compare your current standing with past performance in order to see how your mitigation efforts are working over time.
Summary:
- Define your scope for this year’s statement.
- Map your supply chain.
- Analyze your risk and spending habits.
- Identify your target vendors based on scope.
- Provide insights to target vendors.
- Collect mitigating documentation.
- Collaborate with direct suppliers to propagate upstream.
- Document the mapping, policies, outreach and mitigation efforts.
These are just a few ways that FRDM can help you with your annual statement. If you’re not a FRDM user currently, reach out to our team to discuss how we can help!
If you’re currently a FRDM user, what are you waiting for? Log in and start managing your modern slavery risk!
