Step-by-Step Guide

1. Clear and Unambiguous Policy Statement

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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.

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The policy should comply with:

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• 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).

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

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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.

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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.

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

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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.

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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.

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

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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.

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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.

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📄 Templates and Recommended Resources

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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.

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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:

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• 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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