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Step-by-Step Guide

Implementing a Modern Slavery Prevention Policy

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1. Clear and Unambiguous Policy Statement

Start by drafting a formal document in which Interim Jobs B.V. declares a zero-tolerance approach to all forms of modern slavery, including:

  • forced labor,

  • prison labor used unlawfully,

  • human trafficking,

  • child labor.

The policy should comply with:

  • the UN Guiding Principles on Business and Human Rights (UNGPs),

  • the International Labour Organization (ILO) conventions, such as Convention No. 29 (Forced Labour) and No. 105 (Abolition of Forced Labour).

The statement must be approved by senior management and made publicly available (e.g., published on the company website).

2. Scope and Assignment of Responsibility

The policy should clearly state that it applies to:

  • all employees regardless of employment type,

  • suppliers and subcontractors,

  • business partners,

  • subsidiaries and affiliates.

It is advisable to appoint a dedicated person or compliance/ethics team responsible for:

  • implementing the policy,

  • monitoring compliance,

  • reporting periodically to company leadership.

3. Risk Assessment in Operations and Supply Chains

Conduct a risk assessment to identify where modern slavery risks may occur, especially in:

  • high-risk countries (e.g., lack of labor enforcement, corruption, extreme poverty),

  • vulnerable sectors (e.g., agriculture, construction, care services),

  • business arrangements involving temporary or informal labor.

A risk matrix should be developed, considering geography, sector, and type of supplier relationship (direct vs. lower-tier).

4. Due Diligence Procedures

Implement robust due diligence processes to screen business partners, including:

  • questionnaires on anti-slavery policies and practices,

  • contractual clauses prohibiting the use of forced or trafficked labor,

  • ethical audits when necessary,

  • requiring partners to demonstrate their own compliance systems.

For new suppliers, these checks should be a mandatory part of onboarding.

5. Reporting and Remediation Mechanisms

Develop a confidential and secure reporting system (e.g., trust mailbox, anonymous online form) that enables:

  • employees and stakeholders to report suspicions of modern slavery,

  • protection of whistleblowers against retaliation,

  • clear protocols for investigation and remediation.

Confirmed violations should lead to appropriate corrective actions, such as termination of partnerships, retraining, or legal steps.

6. Training and Awareness

A policy is only as effective as the understanding of those expected to follow it. Therefore:

  • Offer regular training, especially to HR, procurement, and project managers.

  • Use interactive content, including case studies, simulations, and quizzes.

  • Include modern slavery topics in employee onboarding programs.

7. Monitoring and Policy Review

Establish a systematic review process, ideally annually, involving the compliance team.

Recommended steps:

  • define KPIs (e.g., number of staff trained, incident reports, supplier risk assessments),

  • monitor legal changes (e.g., EU Corporate Sustainability Due Diligence Directive),

  • adapt the policy as the company grows or enters new markets.

📄 Templates and Recommended Resources

To make implementation easier, use high-quality templates as a foundation:

  • Spire Safety Consultants – free template for an anti-slavery and human trafficking policy, covering both operations and supply chains.

  • Easy Legal Docs – ready-made anti-slavery policy template suitable for businesses of all sizes (easylegaldocs.com).

  • Rushax – policy example aligned with the UK Modern Slavery Act 2015, ideal for UK-related operations.

Conclusion

Implementing a modern slavery prevention policy at Interim Jobs B.V. is not only a legal necessity but also a mark of corporate responsibility. This process:

  • strengthens the company’s reputation as an ethical employer,

  • reduces legal and reputational risks,

  • supports the creation of a sustainable and transparent supply chain.

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