Compliance in the supply chain is one of those non-negotiable lines in the sand. The question of how you ensure a supply chain is compliant, though, is not one that comes without complications. To start with, you need to be certain what and where you are asking for compliance and what it is to be compliant with?
There are a number of areas where supply chains are required to be transparent and meet national and international standards. These do tend to change regularly, and there is also a very strong possibility that the green agenda will come more to the fore as we start to recover from the impact of covid. Downing Street has been very vocal on the subject of ‘building back greener’, and this will almost certainly lead to tougher enforcement of current laws and the creation of new ones. However, transparent compliance is not always as simple as convenient soundbites and press releases make it sound. Where the chain requires input from countries with less stringent labour and production laws than the UK, ensuring constant and compliant supply is difficult, to say the least. High demand for farmed goods or low cost manufactured products can expose the chain to the potential influence of organised crime as well as low-level false reporting. No matter how rigorous the reporting or how process-driven the system, there are bound to be those who abuse it. Sadly, there is probably little we can do about this. From a reporting point of view, therefore, it will be down to due diligence and being able to honestly state you have done everything possible to ensure you met the compliance standards.
Working with compliance
It is all going to come down to your data in the end because to report and demonstrate compliance, you are going to need clean and up to date information. Just as importantly, though, you are going to need a system that can demonstrate that data in a way that shows its relationship with the requirements of the regulations.
- Write it all down to produce a dynamic, living, compliance policy. A comprehensive and very clear compliance policy is really not negotiable. Remember to set review dates and be flexible enough to respond to changes both in your specific industry and in the wider context. If you can break this down into specific guides on how to meet the standards by department/job role/project, or whatever works best, then so much the better. Practical application is everything, of course, so unless all your team are putting things into practice, all you have is a very complex wish list.
- Get to know new suppliers (and renew old ones) right through your business. Ensure all new suppliers are singing from the same hymn sheet, which is basically your compliance policy as a minimum. Remember to review things regularly with your existing suppliers as well; it’s easy to take things for granted, and that can lead to mistakes.
- Cover everything that matters to your business and know the split between specific and general compliance. Supply chain is a pretty wide-ranging term, so you need to be very specific and know where it is about your industry and where it is about national law.
- Don’t forget your GDPR. In addition to the general and specific laws for your industry, your supply chain data and processing will also need to be fully GDPR compliant.
- People are at the heart of compliance. The Modern Slavery Act (2015) was a milestone when it came to combatting the scourge of human trafficking. No business wants to be associated with any aspect of modern slavery. The number of suspected victims of modern slavery in the UK varies depending on the source of the data. Reported cases are bad enough at just under 10,000, but the Modern Slavery Index puts that at an actual figure of 130,000. For any socially responsible business, of course, one case is too many. As we move away from free movement and into a visa-based system, we need to ensure that we are all vigilant when it comes to confirming data such as right to work and GLAA compliance. Due diligence is the best defence against the spread of forced labour.
We have built in the data compliance and reporting systems you need wherever due diligence and supply chain transparency intersect with your back-office systems. Because compliance is not an option, the processes that support it are not an option for us.
Call us to see how we can help with your supply chain compliance.