Cabinet Office publishes guidance to cut modern slavery from government supply chains

Written by Beckie Smith on 20 September 2019 in News
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Government chief commercial officer says guidance will help officials "work towards eliminating modern slavery" in supply chains

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The Cabinet Office has published updated guidance to help departments identify and avoid the risk of modern slavery in their supply chains during procurement processes.

From 1 October, all central government departments, their executive agencies and non-departmental public bodies will be expected to follow the guidance, which sets out sets out steps officials should take at each stage of the tendering process to minimise the risk of modern slavery.

A procurement policy notice published yesterday said: “Government is committed to tackling the scourge of modern slavery; an umbrella term that encompasses the offences of slavery, servitude, forced and compulsory labour and human trafficking.


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“Departments must take action to ensure modern slavery risks are identified and managed effectively in government supply chains.”

There are an estimated 136,000 people living in modern slavery in the UK, according to the Global Slavery Index.

Elements of the guidance include evaluating how would-be contractors will uphold fair work practices and pay, and asking bidders to explain “abnormally low tenders”.

It also said departments may need to add extra clauses, for which they must seek legal advice, to contracts above and beyond the terms and conditions included in standard government contracts to manage modern slavery risks.

These could include clauses allowing for unannounced inspections, or termination or suspension of the contract where issues are uncovered; requiring suppliers to provide information to demonstrate their approach to modern slavery and human trafficking; or giving departments the right to compel suppliers to agree and deliver an action plan to tackle issues of slavery.

The document also urges officials to consider how their procurement decisions – including requirements for short lead times or high flexibility, downward cost pressure and late payments – could create risks.

But the guidance also tells departments to use a “proportionate” that does “not impose any unnecessary burdens that would deter a wide diversity of suppliers, including small- and medium-sized enterprises, voluntary, community and social enterprise suppliers and those owned by under-represented groups, from competing for public contracts”.

“This means you should not adopt a blanket approach to managing modern slavery risks,” it says.

The Cabinet Office announced plans in March to make businesses bidding for government contracts show they can improve society by tackling big issues such as modern slavery and climate change.

David Lidington, then a Cabinet Office minister, said the move to consider social impact in the tender process would make it easier to identify modern slavery risks in the government supply chain.

“Every year, the government spends £49bn with external organisations and it is morally right that we make sure none of that money goes to any organisations who profit from the evil practices of modern slavery,” Lidington said. That figure has since increased to £52bn a year.

The announcement comes after the Home Office introduced a digital system earlier this month to speed up the process of referring suspected slavery victims to the department. The platform is designed to enable front-line public sector workers – including police officers, social workers, and immigration enforcement staff – to refer victims more quickly.

And earlier this year, the Cabinet Office signed a partnership with the Chartered Institute of Procurement and Supply to provide online courses to commercial officials across government on ethical procurement, including training on how to identify and report modern slavery.

The government will publish a modern slavery statement in December. The Cabinet Office said: “The government statement will set out the actions taken, and plans in place, to identify, tackle and prevent modern slavery in central government supply chains.”

From 2021 onwards, individual departments will each publish annual modern slavery statements.

Government chief commercial officer Gareth Rhys Williams said the guidance would "help public sector commercial teams identify and work towards eliminating modern slavery in our supply chains".

"Tackling modern slavery is a shared endeavour, and one we must work on urgently," he added.

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Beckie Smith
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Beckie Smith is a reporter for CSW who tweets @Beckie__Smith.

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