Modern Slavery Assessment Tool (MSAT) Frequently Asked Questions (FAQ)

1. What is Modern Slavery?
   Modern slavery refers to various forms of severe exploitation and coercion that exist in contemporary society, all around the world. It is a term used to describe situations where individuals are exploited and controlled for the purpose of forced labour, servitude, human trafficking, or other forms of exploitation. Modern slavery can take many forms, including but not limited to:
   1. Forced Labour: People are coerced or deceived into working under exploitative conditions, often without pay or with very low wages. They may be subjected to physical or psychological abuse, restricted freedom of movement, and harsh working conditions.
   2. Human Trafficking: The recruitment, transportation, transfer, or harbouring of individuals through threat, force, or deception for the purpose of exploitation. This can include forced labour, sexual exploitation, or forced marriage.
   3. Debt Bondage: People are trapped in a cycle of debt and forced to work to repay it. Their labour is used as a means of repaying the debt, but the terms are exploitative, and they often cannot escape the situation.
   4. Child Labour: The involvement of children in work that is harmful to their physical or mental development, deprives them of education, and exploits them in various industries, such as agriculture, mining, manufacturing, and domestic work.
   5. Forced Marriage: Individuals, often women and girls, are coerced or forced into marriages against their will. They may face physical, sexual, and emotional abuse, and their freedom and autonomy are severely restricted.
      
      Modern slavery is a violation of human rights and a serious criminal offence in most countries. It is a global issue that affects millions of people, with cases found in both developed and developing countries. Efforts to combat modern slavery involve legal frameworks, awareness campaigns, supply chain risk assessments and reporting, and international cooperation to identify and support victims and prosecute perpetrators.
2. How secure is my data?
   iPRO is independently accredited with the ISO 27001 security standard. Our processes are audited annually to maintain the ISO certification. ISO 27001 is the international standard that specifies the requirements for establishing, implementing, maintaining, and continually improving an information security management system (ISMS).
   The standard provides a systematic approach for managing sensitive company information and protecting it from various threats, such as cyberattacks, data breaches, and unauthorised access.
   
   
3. How was the question set developed?
   The questions, responses and scoring framework are based on the Slavery & Trafficking Risk Template (STRT) developed by the Social Responsibility Alliance (SRA).  The STRT and the iPRO Modern Slavery Assessment Tool are updated annually to ensure that it is reflective of the latest research and evolving industry requirements.
   
   
4. What do I do if my suppliers are identified as high-risk?
   High-risk suppliers generally indicate that there is high inherent risk identified in their business, with very few risk controls to help offset the inherent risk. Suppliers who are categorised as high-risk indicate that further follow up is required. Follow up with high-risk suppliers should be included in your remediation efforts to reduce your Modern Slavery risks. You can view the Individual Supplier Insights of high-risk suppliers to view the action items that should be addressed to lower their risk score in the Modern Slavery Assessment Tool.
   
   
5. What do I do if my suppliers are identified as medium-risk?
   Medium-risk suppliers generally indicate that some risk controls have been identified, but Modern Slavery risks could be further reduced by implementing more controls. Suppliers who are categorised as medium-risk indicate that further follow up is required. Follow up with medium-risk suppliers should be included in your remediation efforts to reduce your Modern Slavery risks. You can view the Individual Supplier Insights of medium-risk suppliers to view the action items that should be addressed to lower their risk score in the Modern Slavery Assessment Tool.
   
   
6. What do I do if my suppliers are identified as low-risk?
   Low-risk suppliers generally indicate that there is very little inherent risk in their business, or they have many risk controls in place to account for the inherent risks identified. Suppliers who are categorised as low-risk should still be followed up as part of your due diligence to discuss the assessment with them and ensure a strong mutual relationship in addressing Modern Slavery risks moving forward.
   
   
7. How do I make sure my suppliers have the documents for policy questions they answered “yes” to in the Modern Slavery Assessment Tool?
   Included in your Modern Slavery Assessment Tool subscription is the Supporting Documentation feature, which enables you to request copies of documents for policy questions that suppliers have answered “yes” to in the Modern Slavery Assessment Tool. Depending on your relationship and any agreements, policies, and codes of conduct you have in place for your suppliers, you could include the provision of such documents as a clause your suppliers agree to and abide by.
   
   
8. What is the difference between the inherent risk score and the unmitigated risk score?
   Inherent risk score is calculated based on the geographical, type of goods, and industry sector parameters that the supplier indicates in the Modern Slavery Assessment Tool. Unmitigated risk score is calculated based on the policy and procedure aspects of the assessment. A supplier can have a high inherent risk score but a low unmitigated risk score, if they have the proper policies and procedures to mitigate the inherent risk in their business.
   
   
9. What does the question "Does your organisation issue a policy/policies explicitly prohibiting workers and agents from procuring commercial sex acts during the length of the contract?" intend to capture?
   The response to this question intends to generate a US Federal Acquisition Regulation Final Rule on Combating Trafficking in Persons (52.222-50) compliance status. This status is relevant for organisations subject to the US FAR due to their role as contractors or subcontractors with the US federal government.
   
   
10. What is the difference between my company’s action plan, and an individual supplier action plan?
    The action plan for your organisation shows the aggregated actions that you can follow up with several suppliers to reduce your aggregated risk scores. It details the core action that needs to be undertaken, how many suppliers it applies to, and the assessment question/s that the action links to. This gives you everything you need to know to take actions across your supply chain.  Action plans can also be viewed from the individual supplier perspective.  The Individual Supplier Insights Action Plan is a useful tool to guide your follow up conversations and remediation efforts with suppliers.
    
    
11. Can I assess my Tier 1 suppliers, Tier 2 suppliers, and any other tiers using the Modern Slavery Assessment Tool?
    Yes. The Modern Slavery Assessment tool only needs a few details about your suppliers to send out an invitation, so if you have their contact details – they can participate. You can use the configurable Groups functionality to label your suppliers accordingly so that you can identify which suppliers are Tier 1, Tier 2, and so on.
    
    
12. How often should I assess my supply chain using the iPRO Modern Slavery Assessment Tool?
    iPRO recommends suppliers be invited to complete the Modern Slavery Assessment as soon as you engage them, and on an annual basis as part of a bulk supply chain assessment.  You can view the reporting dashboards containing the assessment findings anytime during the year or when you need to prepare a Modern Slavery Statement. We also provide the Insights Report up to 4 times per year, and is a snapshot of your supply chain data at the time of reporting. Annual data collection enables you to:
    
    • track supply chain risk over time
    • foster supplier engagement
    • publish updated Modern Slavery Statements that demonstrate progress
    • conduct efficient due diligence
    • review and improve compliance plans
    • prequalify new suppliers for Modern Slavery risk
13. What is a non-responder?
    A non-responder is a supplier who is yet to complete the Modern Slavery Assessment.


14. Is the Modern Slavery Insights report shared with the government?
    No.  We do not share your Modern Slavery Insights Report with any government.
    
    
15. How do I interpret this report?
    This is an aggregate report based on the responses from invited suppliers who completed the assessment.
    
    Each supplier is sorted into a risk category based on their assessment responses and resulting risk scores. You can use the risk categories to determine the distribution of your supply chain across the varying levels of risk.  Suppliers who are yet to complete the report have been categorised as non-responders.
    
    The report provides two scores and in both cases, the lower your score, the better.  These scores provide an objective benchmark that you can improve upon for the next assessment. It is not expected that suppliers will achieve a low score upon their first assessment.  What is important, is using the Individual Supplier Insights to engage with suppliers to encourage actioning of risk mitigations items that will reduce their scores in subsequent assessments, and enable you to demonstrate progress in your annual Modern Slavery Statement.  You can also use your company’s aggregated Action Plan to engage with suppliers and implement specific risk controls as part of your remediation efforts to reduce your Modern Slavery risks. 
    
    
16. How do I use this report for my Modern Slavery Statement?
    It is up to your organisation how you utilise the assessment findings in your Modern Slavery Statement. While the assessment results and Insights Report contain granular detail about your risks and where they are in your supply chain, you may decide that higher level and general statements are more appropriate for inclusion in your annual statement. The aim of the Modern Slavery Assessment Tool is to increase your knowledge of your supply chain, and empower you with data so that you can confidently write your Modern Slavery Statement knowing you have first-hand data from your suppliers.
    
    In general, these are the key ways the Modern Slavery Assessment Tool and Insights Report helps you address the mandatory reporting criteria:
    
    • Geographical maps of your supply chain operations can be included as a key visual to identify your supply chain as part of the reporting requirements. 
    • The supplier Sector data can help you describe your supply chain in terms of Sectors of Operations, and sectors where goods are produced and sourced.
    • Action Plans provide insights into the specific Modern Slavery risks in your supply chain, and you might decide to include general statements about the risks identified through the assessment.
    • The assessment methodology excerpt as well as your own experience with the Modern Slavery Assessment Tool will help you describe the due diligence that you are undertaking to assess your risks. i.e. MSAT as part of your supplier pre-qualification and onboarding, as well as an annual bulk assessment of your suppliers.
    • Action Plans also provide a basis for your remediation efforts to address Modern Slavery risks in your supply chain and you could include general information about how you plan to follow up with your suppliers in the next reporting period to reduce the risks identified in your current reporting period.
    • The aggregated risk scores will help you objectively demonstrate and assess how well your remediation efforts are reducing risks between subsequent assessments.
17. Do suppliers get a copy of their Individual Supplier Insights and Action Plan?
    Yes.


18. Can suppliers change their responses?
    Yes, but this is version controlled.


19. The questions are numbered sequentially, so why are some missing?
    Some questions will only be displayed based on a supplier's response to prior questions.


20. What is meant by ‘provisions you selected in the Policy section’ in question 11?
    Each part of Questions 8, 9 and 10 are policy provisions. There are 15 policy provisions in total. In Question 11, the ‘provisions [the supplier] selected in the Policy section’ refer to all the parts of Questions 8, 9, and 10 that the supplier has responded ‘Yes’ to.


21. Why are there no questions in the ‘Certification’ section?
    Some questions will only display based on a supplier's response to prior questions.


22. What if a supplier has already completed the assessment for another iPRO client?
    If a supplier has completed the assessment for another iPRO client, they will simply have to authorise their assessment responses to be included in the new client’s data set.


23. Can I send reminders from the Modern Slavery Assessment Tool?
    The Modern Slavery Assessment Tool automatically sends suppliers two reminders prior to the due date, prompting them to complete the assessment.


24. Who does the supplier invitation come from?
    The supplier invitation email is technically sent by iPRO, however it displays as though it came from you, and is signed off with your name.


25. How do the Sectors of Operation indicate a supplier’s Modern Slavery risk?
    The reported on ‘Sectors of Operation’ are sectors that are considered to have high Modern Slavery risk, according to the 2017 Global Estimates of Modern Slavery: Forced Labour and Forced Marriage (a collaborative effort between the International Labour Organization (ILO) and the Walk Free Foundation, in partnership with the International Organization for Migration (IOM)), or according to Child Labour: Global estimates 2020, trends and the road forward (Published by the ILO and the United Nations International Children's Emergency Fund (UNICEF)).
    
    If your suppliers are operating in any of these sectors, it is considered a risk.


26. How do the ‘Countries of Operation by risk tier’ indicate a supplier’s Modern Slavery risk?
    The ‘Countries of Operation by risk tier’ refer to risk tiers as set out in the Trafficking in Persons Report, published by the U.S. Department of State, to rank countries based on how well their government addresses Modern Slavery.
    
    If your supplier/s are operating in Tier 2, Tier 2WL, or Tier 3 countries, they are operating in countries where there is less enforcement of Modern Slavery related laws, therefore a higher inherent risk of Modern Slavery occurring.


27. How do the ‘High-risk Goods Sourced’ and ‘High-risk Goods Produced’ indicate a supplier’s Modern Slavery risk?
    Supply chain intersectionality (country produced in/sourced from and the type of good/s) highlighted on the ‘High-risk Goods Sourced’ and ‘High-risk Goods Produced’ maps have been identified by the U.S. Labor Department’s Bureau of International Labor Affairs to have high Modern Slavery risk.
    
    If your supplier/s are producing in or sourcing from any of these specific supply chain combinations, they are participating in a supply chain that has been identified as having high Modern Slavery risk.


28. What does ‘Supplier Countries of Operation by Volume’ tell me?
    ‘Supplier Countries of Operation by Volume’ can be viewed in conjunction with ‘Supplier Countries of Operation by Risk Tier’, to determine how many suppliers share common risks stemming from the country or countries they operate in.


29. Do suppliers have to take action as outlined on the ‘Actions’ page?
    No. The intention of the action plan is to provide suppliers with a list of actions they could undertake in an effort to reduce their Modern Slavery risk.  You may choose to encourage suppliers to review the action items as a general exercise, or specific action items, as you see fit.  In any case, the action plan items are general in nature and should not be considered legal advice.


30. How is an individual supplier's inherent risk score calculated?
    The supplier's inherent risk score is calculated based on responses to question 1 to question 7. Points are added for every response that is associated with an identified modern slavery risk, based on the relevant source material. The amount of points per question are weighted using the Slavery & Trafficking Risk Template (STRT) scoring principles.


31. How is an individual supplier's unmitigated risk score calculated?
    The supplier's unmitigated risk score is calculated based on responses to question 8 to question 20. Points are added for every response that indicated a lack of risk mitigation, based on the relevant source material. The amount of points per question are weighted using the Slavery & Trafficking Risk Template (STRT) scoring principles.


32. How is the aggregated inherent risk score calculated?
    The aggregated inherent risk score is an equally weighted average of all individual supplier inherent risk scores.


33. How is the aggregated unmitigated risk score calculated?
    The aggregated unmitigated risk score is an equally weighted average of all individual supplier unmitigated risk scores.