We need to talk about plastics

It seems like we can’t go a day at the moment without reading or hearing  about the devastating impact of plastics in our aquatic environment. Blue Planet 2 has shocked us all with powerful images of plastics in our oceans, Chancellor Hammond has set out plans to explore new taxing of single-use plastic, Defra is using 1,400 plastic lined disposable coffee cups a day despite Michael Gove promising to urgently tackle plastic pollution when he took over. 83% of global tap water supplies contain plastic fibre, in the UK this is 72%. These fibres are found in honey, sugar, beer, rock salt, fish and are even found falling from the air. We produce 300m tonnes of plastic a year and only 20% of it gets recycled. 8m tonnes enters the oceans each year, and currently, over 5 trillion (yes, trillion) pieces of plastic are floating on the surface of our seas and oceans.

This is an environmental and health disaster happening in front of our eyes. Every day each of us uses, consumes and throws away large quantities of plastics, each of us is contributing to this massive problem. In the UK, 38.5m plastic bottles are used every day – that’s one each, every day, for the entire working age population of the country. Whilst swigging from our drinks bottles, we also get through 2.5bn disposal coffee cups a year.

So what can UK businesses do? Well, I think three things are within reach of most UK businesses:

  1. Get out the bins and work out just how much plastic waste is being produced, how well it is being segregated and recycled – make it easy for your staff to do the right thing with their waste. I have lost count of the number of times we see all sorts of different bins, poorly labelled, in the wrong place, confusing everyone
  2. Look hard at all the plastics used in food/catering/kitchenette operations and for packaging – much of this can be replaced by reusable, bio, recycled options – get rid of the plastic cups, give people re-usable ones, work with food suppliers to change their packaging, get other suppliers to take their plastic packaging back. There are many strategies that will work in any organisation
  3. Make plastic use and waste part of the environmental disclosure and reporting that your organisation undertakes – making this a shared challenge, sharing what you learn is vital – we’re all part of the problem

And… if you’re ambitious, like a growing number of the organisations we work with – set a goal to eliminate single-use plastic from your organisation – it sounds huge but done carefully, this is doable, affordable and an extraordinarily powerful message to staff, customers and suppliers. People instinctively get why it’s important and what they can do to help – it’s a strong, clear, simple environmental message.

At Carbon Smart, we are on this journey ourselves, we’ve got some good waste segregation going on  in the office and the plastic waste we produce is recycled or turned to energy. Our next challenge (and for me personally, a biggy) is to wean ourselves off the disposable plastics that come with buying lunch from local shops.

Make sustaianbility work!

Plastic packaging alternatives – what should you procure?

Plastic, one of the most useful and versatile materials, but also one of the most unsustainable and environmentally damaging. A 2016 study from the World Economic Forum states that each year, over 8 million tonnes of plastic leak into the ocean, which is equivalent to dumping the contents of one rubbish truck into the ocean every minute. If this current pattern continues, it is estimated that by 2050 there will be more plastic in the ocean than fish.

Majority of plastic takes centuries to decompose in the environment and once in the ocean, leach potentially toxic chemicals such as bispenol A and hydrocarbons, which are harmful to not only marine life, but other organisms within the food chain, including humans (National Geographic). Marine species including seals, dolphins and whales are significantly impacted by plastic pollution, with an estimate from Plymouth University stating at least 100 million marine mammals are killed each year from plastic pollution.

The awareness to how detrimentally damaging this material is, is slowly increasing with many companies now taking a stand against un-necessary plastics in their supply chains. Sustainability leaders, such as Sky, have started to remove plastic from their canteen as part of their Ocean Rescue campaign. Increasingly, we see businesses looking to understand how they too can do their bit to minimise the use of plastics, yet not sure where to start.

With nearly half of the global plastic produced used for packaging, it is as good as any place to start with reducing and minimising the use of single-use plastic packaging – the type of plastic most likely to end up polluting our oceans.

There are now a number of sustainable packaging companies that produce alternative products made from plant-based materials (such as Poly-Lactic Acid), an alternative that looks and feels exactly like plastic) or kraft paper products. Not only can these products be disposed of via a number of different routes, for example either straight in the mixed recycling (kraft paper based products) or in the compost/food waste bin (sugar cane and PLA based products), they also decompose at a much quicker rate than any plastic product, making them considerably less environmentally damaging.

But which sustainable packaging products are good? And who produces the best products? Carbon Smart has taken the opportunity to review a selection of products from three companies: Vegware, Biopac and GreenGate. We’ve focused on compostable products, that can be used for takeaways, such as alternatives to the plastic salad boxes used in office canteens and plastic cutlery.


Compostable cutlery

Conversations with our clients have led us to believe that compostable cutlery seem to have a bad reputation – always breaking and not performing as well as their plastic counterparts.  However, if you have already been trialling out the lower carbon intensive compostable takeaway boxes, you may be experiencing the same challenge we often face – employees will dispose of their compostable boxes in the correct waste stream, but will leave their plastic cutlery inside the box, i.e. leading to contamination. We think it’s about time we test out the alternative cutlery options ourselves to see if one of three compostable companies we’ve chosen has a good, robust product.

The best alternative to plastic cutlery we found is the  RCPLA cutlery sourced from Vegware. RCPLA, standing for recycled compostable PLA, is  an incredibly low carbon alternative to other compostable cutlery (CPLA – compostable PLA cutlery), with Vegware stating that these products contain 51% less carbon than new PLA. The cutlery is durable and sturdy, and  performs just as well as plastic cutlery.








CPLA (left) vs. RCPLA in Vegware’s black colour (right)


The compostable cold cup:

A huge contributor to the single-use plastic waste often seen for large businesses is the plastic cup. With many different uses, sizes and shapes, the plastic cup is incredibly versatile.

With PLA cold cups looking and feeling exactly the same as their plastic counterparts, the samples that stood out from all companies tested were the cups displaying slogans. The slogans provide enough information for employees using these cups to realise that they are not made from plastic, and therefore, help to overcome the challenge of correct after use disposal.

A good example is the PLA cold cup sourced from Biopac:









Alternatives to the plastic salad box:

There are a number of different alternatives to the typical plastic salad takeaway box, ranging from the clear PLA container to the 100% kraft box. In comparison to the compostable takeaway boxes mentioned earlier as the cutlery’s new sidekick, the salad boxes are only used for cold food. They need to be leak proof, durable and compete with plastic products.

The kraft boxes were chosen by the Carbon Smart team as the best alternatives, with the main reason being they are more obviously a compostable product in comparison to the PLA lunch container that looks and feels exactly like plastic. Vegware, Biopac and Greengate all produce good kraft box products:

Vegware (top left), Biopac (top right) and GreenGate (bottom)


The main challenge for compostable products is their after-use disposal. The products highlighted in this blog  as the best alternatives have been chosen because they are of the higher quality products on the market, and they also stand out as being compostable.

With so many compostable products on the market that can rival any plastic product, businesses now have the opportunity to review their current procurement decisions and make the change to compostable alternatives. Businesses should be the first to make the swap to single-use plastic alternatives and start to become the solution to  the current global problem of plastics and the detrimental impact they have on the environment. Now armed with this review, is there any other excuse?


Half-baked: where have the Modern Slavery Statements fallen down?

Over 1,800 modern slavery statements were submitted by businesses in the UK to the Home Office as a response to the Modern Slavery Act issued in 2015. Our team analysed those published by the food & beverage sector and learned that there’s a long way to go before these businesses can fully meet the guidelines. 


The Modern Slavery Statements published by businesses in the food and beverage sector show a wide spectrum of comprehensiveness, with many failing to address key requirements of the Modern Slavery Act set by the UK’s Home Office. From our in-depth analysis of the statements published for this sector, only two out of ten meet all the guidelines, and clearly demonstrate the company’s commitment to address and reduce the potential risk of modern slavery in their operations and supply chains. For the rest, there is still a long way to go with many statements  still falling short on a considerable proportion of the requirements.

Understanding what the most common pitfalls are across the sector and where the government guidelines are potentially getting misinterpreted, will provide a vital starting point for businesses to re-evaluate and improve their statements, and ultimately, help to address the key issue – mitigation of modern slavery in supply chains.


What are the four most common pitfalls in the modern slavery statements?

  1. Missing: prominent link on company homepage
    Despite this being a legal requirement of the Act, a surprisingly large amount of companies have not completed this simple step, even though they have published their statements online. Currently one in five businesses have failed to add a link to their homepage and therefore have not complied with regulation. It is a requirement that the statement link is clearly visible to guide viewers. For example, many businesses added the link on the website banner at the bottom of their homepage or in a drop menu at the top of the page. Both are good examples.
  2. Lack of commitment: statement not signed off by senior management
    One in five statements has not been signed off by a director (or equivalent). In such cases businesses have not only failed to meet the legal requirements of the Act, but they also send the message that the business does not take the issue of modern slavery seriously, even if this is not necessarily the case. Due to the gravity of the issue, senior management in every business should be championing their business’s approach to addressing modern slavery in their operations and supply chains.
  3. Unidentified: lack of risk assessment being carried out
    Three out of four statements have not carried out a risk assessment, or at least, have not disclosed that they have. Risk assessments should be the bedrock of a company’s approach to mitigating modern slavery. Understanding where the business’s most material risks are in the supply chain will allow the company to focus their attention and resources where it really matters. This is especially important in the Food and Beverage sector as supply chains are often complex and located in areas of higher risk. Businesses should look beyond their tier one suppliers to fully understand the risks of their supply chain, whilst allowing them to provide more depth to their statements.
  4. Call to action: limited depth of due diligence measures
    80% of businesses have started to outline their due diligence processes in their statements, however many lack depth and do not detail and explain the practical actions being taken. A broad description is often provided and is limited to their immediate business and, failing to have carried out a risk assessment, appear unable to develop and disclose risk focused actions to mitigate risk. Comprehensive due diligence measures should include detailed actions for identifying actual and potential risks, mitigating and addressing these risks and additionally for effective communication throughout the business.

Our analysis of the modern slavery statements by businesses in the food and beverage sector shows that there is still a long way to go for most businesses which failed to meet the Act’s requirements. Addressing such a complex problem as the risk of modern slavery in a global economy is not easy and there is certainly no size fits all solution. In order for businesses to move forward with their statements and to fully address their exposure to risk, and to genuinely address modern slavery, it is essential they first address these highlighted pitfalls. This year, businesses may be able to get away with little commitment, but this will change as stakeholders and customers’ expectations increase.

3 reasons to rethink plastics

With the global plastic production expected to increase to a staggering 1.2 billion tonnes by 2050, it is not surprising that the plastic industry has been described as one of the most essential building blocks of our economy today. This exponential growth will undoubtedly play a vital role in the global economy, however if the plastic value chain continues the way it is, it will have the potential to cause even more detrimental effects on the environment. Changes to our sustainability agendas have to happen, starting with the future of plastics.

Here are my top 3 reasons for rethinking plastics: 

1. Greater than aviation: the huge carbon footprint

The carbon footprint of producing plastic is phenomenal, with more than 90% produced from virgin fossil fuel sources. The huge dependency on oil is leading to plastics being responsible for approximately 6% of the current global oil consumption, which staggeringly, is equivalent to that of the aviation sector. This, as we can all imagine, gives rise to excessive greenhouse gas emissions and if the expected surge in plastic production is to happen, the already huge carbon impact will become even more significant. The World Economic Forum estimates that by 2050, plastics will be responsible for nearly 15% of the global carbon emissions. This predicted increase will lead to plastics overtaking aviation, which is currently accountable for 12% of the global carbon emissions.

2. ‘Take-make-dispose’: low recyclability rates  

Plastics have a very low rate of recycling and reuse compared to other material mainstreams. This is mainly as a result of our economy being built around the linear trend of ‘take-make-dispose’, with many plastic products designed for single use only. Consequently, an enormous amount of waste is produced with more plastics ending up in landfills or incinerated. According to the World Economic Forum, as little as 30% of the plastics produced in the EU were recycled in 2014, leading to 25 million tonnes of post-consumer plastic waste.  Many other countries are beating the UK in the recycling race, such as Germany and Luxembourg, with recycling rates as high as 65%.

3. More plastic in the ocean than fish: the environmental leakage 

The huge amount of waste produced from plastics is causing global waste disposal systems to become increasingly challenged, leading to a large proportion of plastic waste ending up in the environment. It is estimated each year, over 8 million tonnes leak into the ocean, which according to the World Economic Forum, is equivalent to dumping the contents of one garbage truck into the ocean every minute. Plastic packaging is estimated to be the biggest culprit for environmental leakage, due to its size, weight and low value making it prone to uncontrolled disposal.  If no action is taken, predictions are that by 2050, there will be more plastic in the ocean than fish (World Economic Forum).

The production and use of plastics goes hand in hand with the packaging industry, with nearly half of the global plastics produced used for packaging. Businesses must start to actively evaluate the environmental impacts of the plastic packaging they purchase or produce and additionally the benefits of alternative products, such as disposable plastic packaging.  Leading businesses in this area have already taken such steps, for example, Coca Cola creating the PlantBottle – a plastic bottle made entirely out of plants. However, this is only the beginning. We expect that in the next five years, this will become a mainstream assessment of all packaging products – the time to take action is now.


3 eco-innovations in the packaging industry you should know about

The 2017 Packaging Innovations event in Birmingham on 1 & 2 March saw a fantastic line-up of suppliers from the packaging industry who came to show off their newest and most innovative products.  

Carbon Smart attended the event with the quest to find out what sustainable innovations are happening in the industry – and we were not alone. The Ecopack challenge was one of the event’s highlights, where businesses were requested to send in their ideas for sustainable packaging solutions to win the chance to develop their product with M&S. A selected short list of candidates presented their most sustainable innovative packaging solutions to the audience and a panel of judges from retail giants such as M&S, Mars Drinks and Iceland. To give you a flavour of the ideas presented, here is an overview of the flagship products designed by the three finalists fighting for their chance to win:

  1. Kapstone: sustainable lunch trays

Ken Perry from Kapstone was first to present his product under the slogan that their product Kraftpak was the ‘natural choice for sustainable packaging’ – which is a low-density, uncoated, unbleached paperboard grade.

Their flagship case study is called Sustainable food trays. In the US, they propose replacing styrofoam throw away trays with recyclable card trays – their pilot project in the US saved 1.6 million trays / 983,000 pounds of waste going to landfill. Impressive, right? But why is the US throwing away their trays in the first place?

2. Delipac: the recyclable cup

And we are back to paper cups – how could we forget Hugh’s war on waste, where he takes to the streets in his war bus covered in coffee cups with the slogan ‘wake up and smell the waste’. This was in response to the horrifying fact that 2.5 billion cups are thrown away in the UK each year, and 99% of them are going to landfill or incineration.

But not to worry Hugh, Delipac claims that it has the solution for you. The Delipac cup has no internal polymer laminate or liner, meaning that it is 100% recyclable in any paper waste stream, as they say, 100% compostable and 100% biodegradable. And they are robust too – withstanding hot, cold and frozen drinks (even ice cream!).

3. Metsä Board: the Lidloc cup

So, if Delipac has the solution to the cup, what about the lids that go on top? The third candidate, Metsä, a Finnish forest group, specialising in board, pulp and tissue, has a new, innovative solution for us. Metsä has designed Lidloc, the first integrated cup that has an extension structure to the cup that folds and locks into an integrated lid. Can’t picture it? Have a look for yourself: Lidloc.

The design is still in its infancy as the Metsä team still haven’t overcome the polymer barrier, meaning the product is not widely recycled in most paper waste streams. Perhaps Delipac and Metsä could collaborate on getting the Lidloc fully recyclable?

The winner of the Ecopack challenge is still yet to be announced – Ecopack will be announcing this in the next few weeks so stay tuned.

The appetite for sustainable packaging is clearly increasing: the Ecopack challenge event was well attended and many of the businesses representatives at the event told us that sustainability is increasingly climbing up the agenda for their customers. This particularly due to the increasing consumer pressure. Although we are far away from the utopian circular economy for the packaging industry, a large proportion of the businesses we spoke to on the day were able to claim that they have improved the environmental impact of either their products, their operations, or both.

Focus your efforts where it matters: impacts of the food packaging industry

This week BBC Radio 4’s PM programme has been running a series on packaging; how much of it there is, whether there’s too much, how easy it is to reuse and recycle. Much of the focus has been on food packaging.

The journalists have been careful to point out how important food packaging is, and how much of it is a response to what customers want. The demand for food packaging is growing rapidly as we all want more goods delivered to our door and more convenient portion sizes. In developing economies, demand is increasing with people purchasing more packaged food and consumables. The negative impacts of this growing sector are of course growing with it and awareness is key to mitigation.

The environmental impact of the food packaging industry is well understood – the main materials used for packaging are plastics and paper/ cardboard coming from the oil and timber industries, both have very significant environmental footprints. The BBC has explored some interesting ideas for how this impact can be reduced, including giving packaging back, changing the materials used and levying taxes.

But there is another impact that the food packaging industry must wake up to. The plastics and paper / pulp industries and their supply chains are amongst the highest risk sectors across the globe for modern slavery and child labour. The risk of these kinds of workplace abuse rises in sectors where survival for suppliers requires very fast turnaround of orders, ever lower prices and handling of very volatile volumes. The food packaging industry and its supply chain frequently experience these kinds of pressures.

The supply chains of food packaging manufacturers extend across the world into countries where there is a well-documented risk of modern slavery and child labour. Many food packaging manufacturers based in Europe and North America have direct supply relationships in countries such as Eastern Europe, Turkey, China and India, where societal conditions combined with extreme commercial pressure can create dangers for workers. Careful screening, auditing and local engagement with suppliers in these markets help to reduce the risks.

A more difficult problem to tackle, however, is the risk of slavery and child labour further up the supply chain. Working with tier 1 suppliers in countries such as France, Germany, Canada and the USA does not mean that risks are absent. Carbon Smart’s research shows that suppliers to packaging manufacturers in these and other well-regulated countries are themselves at risk through their supply chains. This indirect risk requires a different approach, focused on specific issues, high risk markets and based on transparency and partnership.

As British based packaging manufacturers take on the requirements of the Modern Slavery Act, and others in states such as California face similar legislation, they need to be critically aware that some of the 46 million people in modern day slavery and some of the 160 million child labourers may well be working in their supply chain. It is not possible to address every strand of a global supply chain, yet an approach based on high risk sectors, focusing efforts where it matters and developing open collaborative relationships with suppliers is critical to stopping these abuses. As the BBC programme shows, we are often very happy to moan about the size, shape, colour and material of the packaging our food arrives in, but the food packaging industry and all of us who buy our food packaged need to do more than moan to eliminate workplace slavery and child labour.

5 tips for combating deforestation in the publishing industry

Deforestation is one of the biggest sustainability challenges of this generation. According to Green Action News, 80% of the earth’s forests have already been destroyed. This enormous issue is largely driven by the production of major commodities – including pulp and paper. In fact, the Environmental Paper Institute state that 42% of trees that get cut down are made into pulp for paper products.

The dangers of deforestation are largely well known. However, here are some hard-hitting facts to put the issue into sharp focus:

  • 300 billion tonnes of carbon are stored in the earth’s forests
  • 15% of all greenhouse gasses are a result of deforestation
  • 70% of all animals live in these forests, and 28,000 species are expected to become extinct by 2040 due to deforestation

As terrifying as the above statistics are, they are perhaps not the most surprising. Many people are aware of these dangers. But here is one fact that most people may not be aware of: deforestation is a leading cause of modern slavery.

Walk Free has estimated that there are an alarming 48.5 million people in modern slavery worldwide. The highest risk areas are less developed countries and industries involving raw materials – this applies to the timber industry, specifically the illegal logging side, where there is little to no regulation. Estimates for illegal logging can reach up to 50% of all logging in some countries – so publisher’s need to examine their supply chain with an eagle eye. With the Modern Slavery Act now on the UK statute book, businesses must be extremely diligent to ensure that no slavery is present at any level of their supply chain.

What can be done?

As a publishing company, there are countless ways to ensure your paper is sourced sustainably. There seems to be hundreds of initiatives, certifications and regulations attempting to ensure the sustainable harvesting of our forests. So much so that it becomes easy to feel lost and confused about the best ways to act. Here are our 5 top tips to guide you through:

  1. Using recycled paper – this seems like an obvious choice, still, the benefits are inordinate. Each ton of recycled fibre that replaces a ton of virgin fibre saves 17 – 24 trees.
  2. Understand the full impact of your supply chain – the EU timber regulation requires that all companies must come from a legal source; however, the WWF predicts that over half of timber products traded into the EU are not covered by EURT. Therefore, publishing companies should dig deeper to ensure that the timber they buy is sustainably sourced.
  3. Sourcing certified products – a simple and easy way to ensure that materials are sustainably sourced. The Forest Stewardship Council (FSC) is one of the most widely recognized certification schemes – why not follow in the footsteps of publishing giant Penguin Random House and aim to have 100% of all paper sourced from FSC certified suppliers by 2020?
  4. Become a FSC certified publisher – one step beyond using certified products – getting certified! For this, an FSC chain of custody certification is required, which will enable using the FSC trademark on products.
  5. Collaborating with other suppliers – The UN has heralded collaboration within the industry as a key tactic for ensuring sustainability along a company’s supply chain. By collaborating with other suppliers, publishing companies can become more effective by extending their reach, pools resources, reducing duplication and avoiding conflicting messages.

Understanding the impacts of deforestation and setting out a clear strategy is the key to avoiding the risks associated with deforestation. By having the will to embrace effective recycling systems, by judicious auditing of all elements of its supply chain, and by allying itself to well-respected and reliable certification schemes, the publishing industry can ensure it does not exacerbate deforestation and help to reduce the risks that deforestation already poses.

The click that makes a difference

Why you shouldn’t opt for next day delivery

With Christmas around the corner, suppliers are ramping up production, retailers are introducing extra shifts and customers, wish list ready, are starting to buy presents for their nearest and dearest. Online shopping is a great way to avoid the hustle and bustle of after work shopping – a gruelling experience for many. Research also suggests, that if you don’t have loads of failed deliveries and you don’t return everything you buy, online shopping can be a more sustainable method of shopping.

However, did you know that your choice of delivery method you opt for will have a considerable impact on the environment? Here’s why:

Typically, standard delivery for UK and Europe is transport by road. With standard delivery third party carriers have the time to transport the goods to their main hubs and distribute them from there. However, when you select express, and most certainly next day, road – HGV (heavy goods vehicle) – transport is just not fast enough. So, then there are two options: express delivery vans and flights.

Express delivery vans bypass the hubs and get the orders straight from the retailer to the customers. The vans are smaller and with less goods being transported, meaning that the journey is also more carbon intensive per item transported. For example, let’s say you have ordered a brand-new pair of boots from London coming from Edinburgh, which weigh approximately 2kg. Transporting the goods via standard delivery (road haulage HGV vans) would have an impact of 0.2 kg CO₂e compared to 0.9 kg CO₂e if express delivery vans were used – nearly 5 times more carbon intensive!

Flights, and in particular, short haul flights, are extremely carbon intensive. It is 15 times less carbon intensive to transport goods via road than it is to fly them. Let’s say you decide to order your boots from Madrid instead. By road, a 2kg parcel to Madrid would account for 0.4 kg CO₂e whereas by air it be 5.5 kg CO₂e alone.

A simple purchasing decision, a click-online, can mean that the impact of the transport of your new boots are 15 times more carbon intensive than by standard delivery. So, as you’re planing your holiday shopping, bear in mind the impact of your decisions. If you don’t really need next day or express, use standard delivery – not only will you save the additional costs, but you will also reduce the environmental impact of your Christmas treats.

Modern Slavery statement – the clock is ticking

On the first anniversary of the Modern Slavery Act (MSA), Theresa May, Prime Minister and author of the Act, stated that “Britain will once again lead the way in defeating modern slavery and preserving the freedoms and values that have defined our country for generations” (BBC). The UK government appears very serious about an issue that will not go away without significant action from UK businesses.

As we head towards the end of September, an increasing number of UK businesses are facing compliance with the Act. It requires larger businesses to publish a statement that confirms the steps taken to ensure that slavery and human trafficking are not taking place in the business or in any supply chain, or alternatively to declare that no steps to confirm the existence of slavery or trafficking have been taken. Faced with this challenge, many businesses that have taken first steps to comply have produced ‘holding statements’, high level overviews of a general approach or indeed statements of intent. In many cases, this amounts to a ‘wait and see’ approach; producing a statement without really looking at supply chain risks and waiting to see what competitors, peers and indeed NGOs do next.

Why should businesses avoid a shortcut approach? There are three main reasons:

  1. Modern slavery is likely to exist in most supply chains – research from Ashridge suggests that about 70% of CEOs think slavery is present in their supply chain, some estimates have this higher still. Whatever sector a business operates in or wherever its tier one suppliers operate, any large business will have a supply chain that stretches round the globe into areas where slavery may be present. Codes of conduct only work if they are active, understood and enforced. Every business should be concerned to get this right.
  2. Large businesses have complex supply chains – many large businesses will be looking at supply relationships with more than 1,000 suppliers. It is risky to focus on only a small number of suppliers or to rely on responses to wide ranging supplier questionnaires (if responses do indeed come back). A business may simply miss the areas of real risks and impacts by avoiding a full view of their supply chain. A straightforward mapping of supply chain activity to detailed models of global social risk, such as Carbon Smart’s SPEAR, can provide a solid assessment of where both direct and indirect risks lie and where to focus action. It may not be your biggest or closest supplier that has issues you need to address!
  3. A holding statement is not enough – a short-sighted view is potentially dangerous for a business. Modern Slavery has a profile that it has not had for a very long time, it is a real and present issue for us all. The MSA statement provisions were included in response to UK businesses requesting action – business wants this issue addressed; Major businesses are taking a lead and will expect their suppliers to be doing what they should, consumers expect their brands to be right on this issue, NGOs are very active in looking at statements and the actions behind them – we can expect some businesses to be caught out.  Slavery is not an issue that sits comfortably with white wash statements full of legalese; whatever the letter of the law, the Act is about action.

UK business must once again rise to the challenge. Compliance with the Modern Slavery Act does require a statement, but it is really about action, practical, focused action that will take time to put in place and get right. The clock is ticking and many, many businesses need to act today.

To learn more about the MSA compliance from our experts, or if you have questions, call Ben or Jessica at 0207 048 0450.

Concerned About the Modern Slavery Act?

How should organisations address risks in their supply chain

Discussions around the new Modern Slavery Act requirements have largely focused on what exactly businesses should, or should not, include in their Slavery and Human Trafficking statement. Much of the conversations are around what should be included in the statement, who needs to comply and the timeline for responding to the Act. While the details of getting the statement right are important, Modern Slavery is a much broader issue that all organisations should investigate in their supply chains and address with utmost importance.

Transparency in supply chains is essential for any organisation that wants to tackle this complex issue and there are contradicting views around this topic. Some NGOs are championing transparency and think that in order to address this issue properly, the business community must enter an open dialogue about the challenges, pitfalls and solutions to mitigate the exploitation of people and the risks they are facing in their supply chains. As such, the more transparency and information a business can share, the better. On the other hand, there are advisors and legal firms who aim to minimise an organisation’s exposure to risk rather than identify and mitigate it. This approach could misguide organisations as to the heart of the issue and discourage them from sharing information that may invite public scrutiny.

So how should companies address the Modern Slavery Act and the potential risks associated with it? Based on Carbon Smart’s discussions with businesses since the Act was issued in October 2015, most organisations are keen to do the right thing and address modern slavery in their supply chains. There is a concern with regards to the risks that could come up as part of the process and how they should be disclosed publicly. This concern is justified. A recent survey led by the Ethical Trading Initiative and Ashridge University[1] shows that 71% of businesses interviewed believed that it is likely that modern slavery is happening at some stage in their supply chains. Globalisation has created long and complex supply chains with many players involved, creating a challenging space for businesses to truly understand what is going on in their supply chains.

Identifying these risks, understanding what causes them and developing a mitigation plan are the real challenges the Modern Slavery Act opposes for organisations. Ergon Associates analysed over 200 statements that were published before 31 March 2016 – well before the deadline. The results revealed that 60% of the statements reviewed have not identified priorities based on their risk assessment, and a further 35% did not include any actions required to mitigate modern slavery risks. It may be that some businesses are reluctant to address risks in their supply chains out of fear of what might they find.

For many businesses, the risks are mostly unknown. Businesses’ supply chains are vast, some covering 10,000s suppliers who are not always willing to share information on their sourcing practices. Businesses need to find an approach which will enable them to focus their efforts on high risk areas and start to develop the knowledge and tools to tackle the issues. Once this has been developed, businesses can move onto expanding the scope and scale of their risk mitigation efforts.

Managing risks is an ongoing process that will develop over time. The statement itself acts as a snapshot of what a business has achieved over the course of the reporting year but is only an initial step which will enable organisations begin their journey to tackling modern slavery in their operations and supply chains. Going through the process is important for any organisation and will deliver a clear message to your stakeholders and civil society. Namely, a business needs to demonstrate that it understands its impact on society and has measures in place to stop modern slavery and human trafficking.

Carbon Smart’s goal is to help organisations become aware of the issue, learn whether modern slavery takes place in their supply chains, identify any risks and develop a mitigation plan. We will also help in preparing the statement required by the Act and provide you with useful tools that can be applied by your team members to ensure that modern slavery is not taking place in your organisation.


[1] Source: https://www.ashridge.org.uk/getattachment/Faculty-Research/Research/Current-Research/Research-Projects/Corporate-approaches-to-addressing-modern-slavery/Modern-Slavery-v3-named.pdf