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Modern Slavery Guidance for Personal Protective Equipment (PPE)

This guidance aims to support buyers and suppliers of PPE to tackle modern slavery risks in supply chains.

The Home Office commissioned Impactt, an ethical trade consultancy, to develop the guidance for buyers and suppliers of PPE on the practical steps they can take throughout the commercial lifecycle to identify and mitigate modern slavery risks.

It is intended to support PPE suppliers, including resellers and manufacturers, to provide tailored information on the key measures that should be taken to carry out effective modern slavery due diligence in supply chains.

It is suggested that PPE suppliers should ensure and be able to demonstrate that they:

  • Are transparent about modern slavery risks in the tender applications.

  • Have processes in place to ensure that workers’ human and labour rights are protected, during their recruitment, employment, and repatriation to their home country (specific risks to migrant workers are covered in the document).

  • Carry out due diligence to check that any suppliers that form a part of their supply chains (e.g. sub-contractors or recruitment agencies), are upholding international labour standards.

  • Provide effective remedies to workers, if abuses are identified.

The guidance points out that all suppliers have an obligation to protect workers under the UN Guiding Principles on Business and Human Rights. Throughout the modern slavery risk mitigation and due diligence process, all suppliers should:

  • Engage with workers via interviews, informal discussions, and grievance mechanisms where available, to build a detailed understanding of the issues they face.

  • Consult with workers on appropriate remedy whenever possible/appropriate.

  • Provide workers with access to effective grievance mechanisms and platforms for seeking remedy, including independent (that is, not-company provided) mechanisms where possible.

  • Verify whether action plans have been implemented effectively by speaking with workers and confirming whether the action has made a difference to their lives.

  • Protect workers from harm, including threats and retaliation.

  • In some cases, referral to law enforcement may be necessary to pursue criminal justice, however, this should be done carefully in a manner that protects the workers’ safety and best interests.

  • Provide workers with information on how to access support from local NGOs, worker representatives or law enforcement officials.

The document can be found here.

Impactt UK/Home Office May 2021

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