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ASSENT COMPLIANCECompliance Program for Anti-Human Trafficking


Today’s Presenter

James CalderDirector - Compliance ProgramsAssent Compliance

Over ten years as a senior expert on product stewardship, regulatory approvals/certifications, product safety, and ethical sourcing.


About Assent

• Your Compliance Partner For:

• Ethical Sourcing • Restricted & Declarable Substances • Supply Chain Data Collection,

Inspections and Audits


Assent & AHT

• Ethical Sourcing regulations have many similarities:• Education/Training• Data Collection & Verification• Risk Profiles• Due Diligence• Reporting

• These are Assent’s core areas of focus


Main Legislative Drivers

• Federal Acquisition Regulation (Executive Order 13627)

• California Transparency in Supply Chains Act

• UK Modern Slavery Act


Federal Acquisitions Regulation (Executive Order 13627)

• Federal Acquisition Regulation (Executive Order 13627):• Existing requirements of prohibiting any contractors to engage in severe forms of human

trafficking• Introduces additional prohibitions when using recruiters/agents• Required for all contracts and subcontracts including Commercial Off The Shelf goods• Put into place March 2015

• Compliance Plan• Contractors awarded contracts to provide supplies acquired abroad or perform services

abroad that are valued over $500,000 must develop Compliance Plans to comply with the anti-trafficking regulations and certify their compliance on an annual basis.


UK Modern Slavery Act

• This Act requires companies to produce a "slavery and human trafficking statement" each financial year, disclosing their efforts (or lack thereof) to ensure their supply chains are free from slavery and human trafficking.

• Required for all companies (private and public) doing business in the UK and having over £36 million (Global).

• Applies to good and services.• Must report the business structure, policy, due diligence processes,

areas of risk, KPIs, training.• Goes into effect this month.


California Transparency inSupply Chain Act

• Since January 1, 2012, every retailer and manufacturer doing business in California with annual worldwide gross receipts exceeding $100 million must disclose on its website the extent to which it works to prevent AHT in the supply chain.

• Disclosure to include • Verification (Does it assess the Supply Chain?) • Audit (Does it perform?)• Certification (Do suppliers “certify”?)• Internal Accountability (Internal Procedures?)• Training (Does it train and how?)


Three Regulations: Single Solution


To be successful an Anti-Human Trafficking program should cover the following steps:

Building a Program


STEP 1: Policy Creation


The Policy is your company’s framework detailing your approach to these regulations

• Objective – details the regulations impacting your company• Policy Statement - demonstrates your position• Roles & Responsibilities – defines employees roles• Hotline – provides reporting mechanism• Champion – must be adopted and accepted by senior leadership

STEP 1: Policy Creation


The policy needs to be clearly communicated to the company’s employees and supply chain. For due diligence purposes, the awareness program should include methodologies to capture data that proves the appropriate individuals within the supply chain have reviewed and understood the issue of human trafficking and how the policy addresses the issue.

STEP 2: Awareness Program


Broadcasting your company’s policy and requirements to address Anti-Human Trafficking

• Develop & Distribute Educational Materials – creates awareness for internal employees as well as suppliers to ensure they are monitoring activities

• Communicate Requirements – inform the supply chain of the requirements and actions that constitute a violation of your policy

STEP 2: Awareness Program


The policy needs to ensure that any employee can report on potential risk or incident of human trafficking and be completed free from reprisal. The reporting mechanism needs to take into account, if applicable, the language and technological accessibility of the company’s employees.

STEP 3: Reporting Hotline


• A Reporting Hotline provides employees, suppliers and contractors a way to report issues, ask questions and provide assistance

• Address Confidentiality – Explain the measures taken to ensure any information provided is done so in confidence

• Provide Instructions – Reporting is only as good as the detail provided so its important instructions are given in order to demonstrate what’s needed for a company to take action

STEP 3: Reporting Hotline


STEP 4: Supply Chain Risk Assessment


Assessing your vulnerability to Human Trafficking issues within your supply chain will help eliminate risk

• Create a Sourcing Map – certain geography locations pose a greater risk to the potential for Human Trafficking

• Identify Supplier/Contractor Practices – through the use of questionnaires and audits document the hiring practices of your supply chain

• Include your business operations

STEP 4: Supply Chain Risk Assessment


STEP 5: Mitigation Activities


Exposure of any potential issues requires an action plan to change the practices of the supply chain or eliminate the source

• Questionnaire/Audit Review – evaluate supplier responses and work with them to eliminate hiring practices that create risk for Human Trafficking violations

• Share Requirements Annually – pass along your supplier code of conduct and educate suppliers on the need for ethical practices

STEP 5: Mitigation Activities


STEP 6: Incident Management


Create a process by which your organization can properly assess and resolve any instances of human trafficking

• Manage incidents reported through hotline, HR, or other avenues• Assigns ownership (case management) to identify, analyze, and correct any

exposure to human trafficking• Reporting of incidents

STEP 6: Incident Management


STEP 7: Continuous Improvement


• Demonstrate your company’s continued efforts to improve supply chain transparency, promote education and awareness on the topic and reduce supplier risk.

• Year-Over-Year Improvement Opportunities: as the program gets started document ways in which your company can improve its processes and communication within the supply base.

• Increased Audit Verifications: create a plan to add supply chain audits to your annual process.

• KPIs: document your supplier risk and track your decrease in risk level as the program matures.

STEP 7: Continuous Improvement


STEP 8: Due Diligence


The verification process by which a company ensures its program is robust, adopted by the supply chain, promotes transparency and meets the requirements of the relevant regulations

• Program Completeness: understand the reporting requirements, define execution

• Transparency: ensure your internal processes are auditable and expectations to your suppliers are understood and able to be followed

• Process Documentation: how your company and supply chain will handle situations as they arise

• Has to include some validation/challenge to areas of risk• Applies to all steps

STEP 8: Due Diligence


Your Next Steps

Consult with Counsel

Build a Program Select Tools& Execution


How Assent Helps

All the tools you need…


The Assent Platform


Turnkey Services

• Assent can manage the entire program end-to-end

• Costs: Less than cost of using internal teams and resources

• Scope dependant• Contact

[email protected] for a quote

mailto:[email protected]


Assent Platform OverviewTuesday, October 20th, 1PM EST


Documents

Assent Compliance · • Manage incidents reported through hotline, HR, or other avenues • Assigns ownership (case management) to identify, analyze, and correct any ... and reduce