Benet Northcote: 'We can’t eradicate slavery without appreciation of human rights'

The John Lewis Partnership’s Director for Corporate Responsibility, Benet Northcote discusses the human rights agenda and what the UK Modern Slavery Act means for business.


What the Modern Slavery Act means for the John Lewis Partnership – is it a risk or an opportunity for business?

It’s about human rights, it’s non-negotiable. This is simply about the way we should be behaving as actors in civil society. It shouldn’t be classified as a risk or an opportunity.


Do you think the Modern Slavery Act somehow changed John Lewis Partnership’s approach in this space?

We’ve always taken these issues seriously. I think there is no question however, that the Act has sharpened focus on the issue of modern slavery and human rights. It raised awareness of the issue and challenged all large businesses to take action.


What do you see as the biggest challenges in implementing the Act and what are the challenges of the broader slavery work?

The way the Act is framed is very simple – complying with the basic elements of the Act isn’t that challenging. What’s more challenging is complying with the spirit of the Act. And that does require a broader understanding of the underlying causes and risks around modern slavery. That’s why we’ve been very clear to link our modern slavery response to our business strategy on human rights. If society is to successfully eradicate slavery, one can’t pretend that targeting that as a single issue is going to remove the systemic causes.


Incorporating modern slavery – which is one of the most severe breaches of human rights – as part of a broader strategy on respecting people’s human rights throughout global supply chains will unlock and address instances of labour abuses.


What does implementation of the act look like?

There isn’t one answer to this. All businesses have to understand where the greatest risks are in their operations and supply chains and where they can have the most influence and can make the most difference. It’s important to go above and beyond the basic audit or compliance in the areas where we can have a particular impact. Also no one business can address this alone: collaboration is essential.


We have engaged NGOs and experts in developing our human rights strategy and in delivering the projects that we are running. Waitrose is partnering with the Wilberforce Institute on assessing the risks in fresh produce. John Lewis is running a model factory programme in the UK. It was launched at the Fast Forward employment practices workshop in January with ten bedroom, upholstery and fitted kitchen suppliers taking part. We have engaged a specialist assessor to undertake the forensic employment practices and HR systems assessment at each site and each factory are testing a mechanism for workers to confidentially share thoughts, feelings and views about the employer and the place they work. However, for all businesses it’s about understanding their point of influence, trying to drive ambitious improvements and sharing learnings and being honest about what works and what doesn’t.


Who is responsible for anti-slavery work at the John Lewis Partnership? Where does it sit in the organisation?

We have a formal governance structure and process. Ultimate responsibility sits with the Partnership Board and is delegated through the management board to teams within our trading divisions.  The formal delegation and senior accountability is important in a retail business to ensure that the activity is embedded in how we operate.  For example when you’re dealing with suppliers, it has to be managed by supplier relations and merchandising teams. They are the ones who understand the technical specifications, such as quality of products as well as buying goods and services. They are also the ones who understand what the solutions could be.


Some of the biggest scandals tend to be connected to human right violations. In the era of ever growing corporate transparency, what’s the best way to handle the labour crisis?

The starting point has to be understanding the situation, what has happened and focusing on helping the people impacted by the labour abuse. It’s not always clear what the immediate answers are, but working with the supplier to rectify the situation and drive improvements has to be the objective.


You have to have a robust approach on how you tackle modern slavery and you shouldn’t be afraid of understanding what the issues are and working to help those victims of modern slavery as well as other companies further down the supply chain. Simply walking away isn’t the answer. Working with the police, NGOs and any other actors involved to try to find the best solution for the individuals is the way forward.


What is the role of digital and technology in addressing slavery?

Technology is going to drive the level of supply chain transparency that we haven’t seen before. The potential for our ID tagging or other technologies that are harder to get your head around – these are clearly the technologies that are going to make a difference to the way supply chains operate going forward.


Will technology on its own wipe out crime? I don’t think so. I think at the end of the day a criminal will always find a way of distorting the law.


How to get started? What would you advise to someone starting the journey?

Firstly, putting the effort in to map out your supply chain early is tremendously important. Secondly, it’s key to understand what it is that you do in the sector best. Identifying the point of influence, areas where you’ve got the most impact is the next stage. Then you can dig down and understand the problems in those areas and put in place programs to explore and address those challenges.


I don’t think we can eradicate modern slavery without a deep appreciation of human rights.


Benet Northcote is Director for Corporate Responsibility at The John Lewis Partnership. 

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Modern slavery and what it means to business

The Modern Slavery Act came into force in October last year directly affecting 12,000 UK businesses as well as creating knock-on effects for many others worldwide. 


Its purpose is clear and its motivation is laudable. More challenging, however, is identifying the extent to which businesses are affected and how they can best tackle this far reaching and important issue. 


What the act means


The term modern slavery encapsulates offences covered in sections 1 and 2 of the act: 

  • Slavery, servitude and forced or compulsory labour, as set out in the act
  • Human trafficking


It is based squarely on the principle that companies should be taking steps to prevent slavery from occurring. Where it does occur, organisations should assume accountability and work with suppliers to improve practices and minimise future risk. It follows on from the UN Guideline Principles on Human Rights, which takes the view that businesses should mitigate risks posed by business relationships. 


Compliance requirements


A key element of the act is the transparency in the supply chain clause, requiring companies affected to publish a slavery and human trafficking statement within six months of each financial year end. 


This statement must specify actions taken by the company to ensure that slavery and human trafficking are not present in any part of the business or supply chain. 


It is a legally binding requirement that applies to companies that fall under all of the following – whether in the private, public or non-profit sectors: 

  • Operating in the UK, whether incorporated here or elsewhere
  • Have a turnover of £36m or more per year 
  • Providing goods for sale or service


The statement needs to include one of the two following declarations. Either:

  • ‘Steps are taken to ensure slavery and human trafficking are not taking place within the supply chain or any part of the business’


  • ‘The organisation has not taken any such steps’.


The statement could also include:

  • Information about the organisation’s structure
  • Business and supply chain policies
  • Due diligence processes and staff training in relation to slavery and human trafficking
  • Risks identified and steps taken to manage such risks
  • Effectiveness in ensuring slavery and human trafficking is not taking place


It must be must be published in the organisation’s annual accounts and placed on its website with a prominent link on the homepage. Any businesses without a website must provide a copy of the statement in writing within 30 days to anyone who requests it.


The first to report under the act will be businesses with a financial year end of 31st March 2016, with statements required by the end of September this year at the latest. Non-compliance can result in court injunction, forfeiture of assets, reparation orders, an unlimited fine and even sentencing.


Getting started


Organisations affected by the act and focussed on maintaining their reputations should be trying to show that they have taken steps to address these issues.


It is generally difficult for businesses to ensure their supply chain is slavery-free. By its very nature slavery is secretive and the complexity of many supply chains makes it harder to identify. 


But organisations with robust stakeholder management should already be well on their way to addressing these issues. Others may need to direct more time and resources towards this area.


The following steps are a useful guide:

  1. Map your supply chain
  2. Identify areas of greatest risk – and greatest potential for improvements 
  3. Set targets and allocate resources to tackle the issue
  4. Prioritise remedial issues
  5. Develop a long term strategy and code of conduct
  6. Evaluate, report and communicate regularly


Beyond compliance


Forward looking organisations will also be quick to recognise the brand and reputational risk associated with this act. More than being solely a compliance issue, the need to include a statement within financial reporting and accounts – and show meaningful progress – will have the effect of shining a spotlight on a controversial issue.  


As a result of the act, slavery reporting is now even more of a transparency issue, one where wide-reaching and decisive action will head off unwanted investor, stakeholder and media attention as well as contributing to a more equal society. It’s also a timely opportunity to look at wider human rights issues, such as child labour and diversity, and their impact on supply chains.


For more information on whether your organisation falls within the scope, visit the Modern Slavery Act 2015 website


Murray Sayce is Principal at Ramboll Environ.

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