59 Virtual Brochure – March 2025 Accountability, responsibility and oversight of Modern Slavery Act compliance Institutions may not adequately assess the risk of compliance with the Act and / or evaluate its compliance on an ongoing basis due to a lack of ownership of this area. We have observed: • A lack of tangible corporate ownership. Executive level sponsorship should set the tone and expectations at a strategic level and provide a link between the board and professional services with operational responsibility. • The absence of clearly and formally assigned operational ownership for oversight and compliance with the Act and what this means in practice, i.e., the areas and activities that sit behind the content of institutions’ statements. • Modern slavery can typically be seen as a finance and procurement concern, given the supply chain connotations. It needs to be recognised that risks extend to a range of business areas and activities, including staff and students. • Consequently, statements are often produced in isolation, usually by procurement teams, and sometimes a single individual, with limited input and review by other impacted business areas. Greater collaborative input from across the institution in preparing the statement provides a more holistic view of the business and for progressing institutions’ modern slavery agenda more broadly. • Lack of prioritisation for progressing work in response to modern slavery risks due to resource constraints or reprioritisation. A cross-functional modern slavery working / oversight group provides an opportunity to enhance oversight of the preparation of institutions’ statements, risk identification and mitigation activities, and foster a more comprehensive and coordinated risk management approach. Such a group should incorporate student and academic and research staff representation, as well as those business areas giving rise to high(er) risk of modern slavery.
RkJQdWJsaXNoZXIy NTI5NzM=