3: Risk assessment, prevention and mitigation

Key Content

Level 1

• List of the most salient, severe and tractable modern slavery risks initially identified
• Overview of existing risk assessment policies and procedures, noting where they are relevant to modern slavery and where responsibility resides for them within the business

Level 2

As Level 1, plus:

• Modern slavery risk register that is regularly reviewed by the Board or equivalent
• Analysis of organisational leverage to address priority risks, including degree and kind of responsibility
• Evidence of engagement with workers’ organisations to help identify risks

Level 3

As Level 2, plus:

• Evidence of ongoing revision and refinement of modern slavery risk register and associated policies and procedures
• Preventive approach to managing risks

Suggested information to include

• Risks may be disaggregated by: country, region, sector, relationship (with supplier, contractor, partner), good or service supplied
• Data on likely risks associated with e.g. country or region taken from authoritative sources such as the US State Dept Annual TIP Report; ITUC Human Rights Index, Global Slavery Index
• Identification of known severe and tractable risks (i.e. where the business can do something about them)
• What constitutes a priority or tractable risk should be proportionate to the size, capacity and degree ofresponsibility borne by the organisation
• Description of engagement with internal and external stakeholders (e.g. buying teams, regional teams, regional NGOs and trade unions) in understanding and prioritising risks