Modern Slavery Bill: transforming construction CSR and supply chain management.

No responsible organisation in construction would want any association with modern day construction slavery, forced employment, child or migrant exploitation as we read increasingly often in the mainstream news, for example Qatar construction or closer to home with construction gangmaster organisations. Hence the Modern Slavery Bill should be welcomed by the built environment sector.

Included within the Modern Slavery Bill introduced on 31 August 2015 (coming into affect on 31 October 2015) is a clause that has significance for most construction organisations – the Transparency in Supply Chains (TISC) clause.

We have introduced a transparency in supply chains clause to the Modern Slavery Bill. This will require businesses above a certain size threshold to disclose each year what they have done to ensure that there is no modern slavery in their supply chains and own business. This will be a truly world-leading measure. There are similar transparency requirements in California, but they only apply to businesses producing goods for sale, whereas this disclosure will apply regardless of what it supplies, whether goods or services.
Minister for Modern Slavery and Organised Crime, Karen Bradley

What does the Bill and Transparency Clause mean for construction:

Chris Blythe, CE CIOB in Foreword to the CIOB Dark Side of Construction publication: The dark side – the systematic exploitation of millions of vulnerable migrants – is rarely acknowledged, even by the clients and multinationals that commission and create our shiny new cities. Our sector is rife with human rights abuses. Bonded labour, delayed wages, abysmal working and living conditions, withholding of passports and limitations of movement are all forms of modern slavery.

The scope of the TISC clause will cover construction products companies importing goods or components to the UK, as well as contractors and consultancies operating in the home markets and/or overseas.

The Modern Slavery Bill (with its Transparency in Supply Chains clause) will transform and elevate construction CSR and Supply Chain Management as important legislative responsibility processes.

Organisations with a turnover of £36 million will have to:

  • publish a “slavery and human trafficking statement” setting out the steps it has taken to ensure that slavery and human trafficking is not taking place in its supply chains and within its own business.
  • From October 2016, to publicly share their policies and strategies to tackle modern slavery in their supply chains.

Guidance on what might be included in such a statement:

  • Companies’ due diligence processes relating to slavery and human trafficking in their supply chains;
  • Reporting on the parts of companies’ supply chains where there is a risk of slavery and trafficking taking place, and how to assess and manage such a risk;
  • Reporting on staff training on slavery and human trafficking;
  • Reporting on companies’ effectiveness in ensuring that slavery and trafficking are not taking place in their businesses or supply chains.

“Implications of non-compliance with this reporting obligation in such a morally compelling context could leave a large dent in an otherwise sterling company reputation” Victoria Ball, projects & construction associate at law firm Trowers & Hamlins

“It will involve a deep dive into the supply chain to understand what’s really going on many tiers down – getting visibility of the many layers to truly see the conditions of workers at the bottom of the chain. The message to companies is clear – it is no longer an option to stay below the radar, refuse to take responsibility for problems in your supply chain and hope you won’t get exposed.”Cindy Berman, head of knowledge & learning ETI

What is not so clear is where the responsibility under the Bill rests for SME’s below the threshold that have organisations above the threshold within their supply chains. Most construction organisations procuring goods and services from large product distributors or manufacturers.

Actions construction and built environment organisations should take?

  • Embed Modern Slavery into CSR policies and statements, where, arguably there should be a statement anyway if base on a recognised CSR structures(eg ISO 26001, Global Reporting Initiative (GRI), JUST, Global Compact or the Human Rights Charter)
  • Understand the concept of Transparency in Supply Chains (TISC)
  • Include questions statements in supplier procurement processes. (And probably best to do so for all suppliers who are close to or over the threshold)
  • Develop a PQQ and Project Bid standard text.
  • Understand what an annual“slavery and human trafficking statement” for your organisation could look like

And of course, these good practices should be adopted even if below the £36million turnover threshold as a matter of social responsible construction.

Sources:

Related iSite blogs:

JUST: a social justice label for construction …

Constructing CSR iTransparency 

Understanding CSR in Construction

Heros and Texts for a future Built Environment based on #CSR

“suddenly the air smells much greener now”

Listening to ‘These Streets’, lyrics by Paolo Nutini summed up the brilliant, inspiring Green Vision conference in Leeds – exploring CSR within the built environment.

A mix of talks, presentations, round table discussions and pecha kuchas from Mel Starrs, Eden Brukman, Tamara Bergkamp, Eddie Murphy, Martin Brown, Faye Jenkins, Claire Walker, Rick Hamilton, Mark Warner, Pedro Pablo Cardoso-Castro, Andy Ainsworth, Paula Widdowson and many others showed that there is real emergence and a future for a Built Environment founded on social responsibility principles.

The air smells much greener …

We heard of excellent progress being made by individuals, projects and organisations on the CSR journey, and how behind these are great influential thinkers, often outside of the sector, many, unsurprisingly, related to the ‘outdoor’ sector.

Many of the speakers were enthusiastic in sharing CSR heros and recommended CSR reading. So here, as a summary, or reading list are those mentioned during the day. I wonder how many of these are on the reading list within design, construction and fm education? (Book titles link to Amazon)

Yvon Chouinard

Rock climber, environmentalist and outdoor industry businessman, noted for his contributions to climbing, climbing equipment and the outdoor gear business. His company @Patagonia is widely acclaimed for its environmental and social focus. According to Fortune magazine, Chouinard is arguably the most successful outdoor industry businessman alive today.

The Responsible Company What we have learnt in the first 40 years at Patagonia by Yvon Chouinard and Vincent Stanley (see my blog)

Let My People Go Surfing Yvon Chouinard – Probably the ‘must read book’ to understand CSR in Business

(On my blog: How can construction learn from Patagonia?)

Ray Anderson

Founder of Interface Inc., one of the world’s largest manufacturers of modular carpet for commercial and residential applications and a leading producer of commercial broadloom and commercial fabrics. He was known in environmental circles for his advanced and progressive stance on industrial ecology and sustainability.

Ray was was posthumously awarded an Outstanding Achievement award at this year’s Guardian Sustainable Business Awards in 2012. (There is a related, must watch, video here: John Elkington describing the work and legacy of Ray Anderson)

Confessions of a Radical Industrialist: Profits, People, Purpose: Doing Business by Respecting the Earth (2009) Later released in paperback as Business Lessons from a Radical Industrialist in 2011.

Paul Hawken

An environmentalist, entrepreneur, and author. Ray Anderson of Interface credited The Ecology of Commerce with his environmental awakening. He described reading it as a “spear in the chest experience”, after which Anderson started crisscrossing the country with a near-evangelical fervor, telling fellow executives about the need to reduce waste and carbon emissions.

Hawken’s book, Natural Capitalism: Creating the Next Industrial Revolution (1999) coauthored with Amory Lovins and Hunter Lovins, popularized the now-standard idea of natural capital and direct accounting for ecosystem services, a theme revisited by Rio +20 and likely to become more mainstream across the built environment.

Janine Benyus

Her 1997 book Biomimicry: Innovation Inspired by Nature defines Biomimry as a “new science that studies nature’s models and then imitates or takes inspiration from these designs and processes to solve human problems”. Benyus suggests looking to Nature as a “Model, Measure, and Mentor” and emphasizes sustainability as an objective of biomimicry. Key thinking in the Living Building Challenge principles, as is

E O Wilson

Edward Osborne Wilson an American biologist, researcher, theorist, naturalist and author. In the mid 80’s developed the concept of Biophilia, the connection between humans and nature, which translates into architecture and the built environment as comfort, well being and productivity through exposure to natural light and natural surrondings or imagry.

Anita Roddick

Dame Anita Roddick, human rights activist and environmental campaigner, best known as the founder of The Body Shop, a cosmetics company producing and retailing beauty products that shaped ethical consumerism The company was one of the first to prohibit the use of ingredients tested on animals and one of the first to promote fair trade with third world countries. Roddick was involved in activism and campaigning for environmental and social issues, including involvement with Greenpeace andThe Big Issue.

John Elkington

John Elkington @volansjohn is a world authority on corporate responsibility and sustainable development. He is currently the Founding Partner & Executive Chairman of Volans, a future-focused business working at the intersection of the sustainability, entrepreneurship and innovation movements

His latest book The Zeronauts, Breaking the Sustainability Barrier describes many of todays inspirational leaders : “Just as our species broke the Sound Barrier during the 1940s and 1950s, a new breed of innovator, entrepreneur, and investor is lining up to break the Sustainability Barrier”

Jorgen Randers

2052: What will the world look like in 2052

Jeff Hollender,

Jeffrey Hollender is an American businessperson, entrepreneur, author, and activist. He was well known for his roles as CEO, co-founder, and later Chief Inspired Protagonist and Executive Chairperson of Seventh Generation Inc., the country’s largest distributor of non-toxic, all-natural cleaning, paper and personal care products. www.jeffhollender.com/

Gary Hirshberg,

Gary Hirshberg is chairman and former president and CEO of Stonyfield Farm, an organic yogurt producer, based in Londonderry, New Hampshire. Now part of the Danone group.

Published in January 2008, Stirring It Up: How to Make Money and Save the World is a book about socially minded business that calls on individuals to realize their power to make a difference in the marketplace, while doing business in ways that adhere to a multiple bottom line – one that takes into consideration not only finance, but the environment and health as well.

Jeffrey Swartz,

Jeffrey Swartz is the former president and CEO of The Timberland Company an organization that believes that doing well and doing good are inextricably linked. Timberland’s commitment is to reducing global warming and preserving the outdoor environment.

David and Claire Hieatt,

Founders of Howies a clothing company based in Cardigan Bay, Wales produces eco-friendly T-shirts, jeans and sportswear, and aims to have ethically correct practices. Howies use natural fabrics as alternatives to petrochemical-derived modern fabrics. Examples include organic cotton, Merino wool and recycled cotton. Howies T-shirts often have images or slogans with political or environmental themes

Dee Hock

Dee Ward Hock is the founder and former CEO of VISA , described systems that are both chaotic and ordered, and used for the first time the term “chard” and chaordic,combining the words chaos and order.

More?

Over to you –

Follow the discussion on twitter with the #GVis2012 hashtag.

Who are your CSR Heros and CSR Texts to add to this Built Environment inspirers list?

What additions or comments would you make to the entries above?

A full record (video, blog, tweets, presentations, storify) of the Building CSR Event is being curated on the be2camp event page here.