2: Policies in relation to slavery and human trafficking

Key Content

Level 1

• List of relevant policies, describing what they cover and how they relate to modern slavery; policies should be aligned with the ETI Base Code or other codes based on international labour standards
• Plan to develop specific policy on modern slavery (and, as relevant, on related issues – see yellow slide) or plan to include these issues in existing policies
• Information on how policies are communicated and enforced

Level 2

As Level 1, plus:

• Evidence of specific policies on modern slavery and (as relevant) on related issues or evidence that these issues are addressed in existing policies
• Reference to assessment of supplier human resource policies and practices

Level 3

As Level 2, plus:

• Evidence that input from external stakeholders has contributed to the development of a specific modern slavery policy or the inclusion of modern slavery concerns within existing policies
• Evidence that modern slavery is mainstreamed in all relevant HR, purchasing and sourcing policies and practices

Suggested information to include

• Codes of conduct for: employees, suppliers, contractors, business partners
• Human resource policies (recruitment, pay, etc.)
• Purchasing and procurement policies
• Specific policies on issues relevant for the reporting organisation (such as homeworkers, migrant workers, child labour, remedy for victims of labour exploitation, etc.)
• Policies on freedom of association and collective bargaining
• Information on how employees, suppliers etc. can access relevant policies (including where their nativelanguage is not English and/or local literacy rates are low)
• Enforcement mechanisms for policies – this is particularly important since policies only matter to the extent that they are put into practice
• Assessment of relevant policies from third party organisations (suppliers, contractors, partners)
• Processes for development, sign-off and ownership of policies within business