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Bank Australia set a great example in their response to the challenge of dealing with human exploitation in business' supply chains. They were highly committed to training their people on this topic, emphasising to staff both the ethical responsibility we all share to stamp out human exploitation and the practical actions that individuals and organisations can take to act now.
With the introduction of the Australian legislation in 2018 and its first reporting period running from July 2019 to June 2020, Australian businesses were confronted with a steep learning curve in complying with the complex requirements of investigating their supply chains, supply chains where opacity in lower tiers (ie the suppliers to their suppliers) had never before been considered problematic.
GRC Solutions consulted industry partners and clients on the need for a training response to this challenge. It quickly became clear that there was a strong desire on the part of organisations within our own networks for training on this important topic, and for us to equip their staff with a practical understanding and skills to navigate the ethical and operational challenges posed by modern slavery. Our initial intention was to develop an online e-learning package directed at purchasing officers to alert them to the dangers of modern slavery in their supply chains and train them on identifying and avoiding them.
Client and partner feedback indicated that training needed to be developed for:
In addition, clients indicated the need for a general training course that would illuminate best practices in combating modern slavery, alongside training that was directed specifically to the Australian business community.
To meet industry expectations we undertook a four-pronged interrelated approach to this training:
The intention was for these four approaches to develop a cumulative, rolling awareness of modern slavery as an important issue for our client networks, and to reinforce through spaced learning and repetition through multiple platforms the practical actions that individuals and organisations can take to combat and prevent human exploitation.
GRC Solutions team includes lawyers with extensive compliance experience, one of whom also has experience in issues relating to modern slavery law. We applied this team’s expertise to the development of a three-module, online e-learning product on modern slavery.
GRC Solutions,modern slavery expert, Deidre Grover, partnered with Kimberly Randle of FairSupply, an Australian modern slavery compliance specialist company, to deliver a series of free webinars and workshops.
The webinars, Modern Slavery and Your Business and Issues Arising in the Lead Up to the End of the First Reporting Period, were delivered in May 2019 and May 2020 respectively. The first outlined the steps businesses need to take in order to be ready for the commencement of the first Australian reporting period. The second was designed to assist compliance staff with an understanding of the amount of detail to include in their first report, and how to respond to recent Border Force announcements relating to Modern Slavery.
A free, lunchtime workshop was held in Perth in July 2019. Entitled ‘Modern Slavery’, it was designed to raise industry awareness of the urgency of addressing the issue. The event was fully subscribed with 45 people attending. Feedback was extremely positive, indicating that participants felt they had gained a clearer understanding of the developing requirements in these areas.
These are a subscription product, mainly marketed to the Financial Services sector. A total of 11 Compliance Notes were issued from 2018 to 2020 relating to Modern Slavery, covering issues including the timeline for implementations, the scope of the legislation and regulator guidelines on compliance.
The overarching aim of GRC Solutions’ Modern Slavery training project was to develop an urgent, constant and consistent message about the existence of human exploitation, and to empower people within our clients’ organisations to do something practical about it from the perspective of their own job roles and capabilities. This aim appears to have been achieved, judging by the feedback obtained by clients.
There was a major response to all aspects of our ModernSlavery training, from the traditional e-learning course to the Compliance Notes.
A case in point was the example of Bank Australia, which enrolled their relevant staff in the e-learning, with a 100% completion rate.
Almost 1500 recipients read the Compliance Notes on modern slavery. 300 people initially attended the webinars (with thousands of viewers having access to the webinar on GRC Solutions’ website afterwards). 45 people attended the lunchtime presentation.
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