10 Voices, 10 Strategies: Unveiling Modern Slavery Risks in the Financial Sector

Featuring Jana Sherrin, ESG Supply Chain – Modern Slavery and Human Rights Lead.

I’m the Supply Chain Lead for Modern Slavery and Human Rights at a multinational universal bank, and today, I’ve been tasked with discussing strategies the financial sector can deploy in its due diligence processes.

Complacency in modern slavery awareness

In the financial sector, modern slavery is often seen as a financial crime issue, not as a supply chain priority. This leads to the first significant risk: complacency. Many assume modern slavery only occurs in distant, complex private supply chains. However, thinking something is low risk or non-existent is a dangerous position. Forced labour and child labour can and do occur across industries.

Aligning with human rights frameworks

For the financial sector, with its vast and complex global supply chains, it’s essential to align with existing human rights frameworks, such as the United Nations Guiding Principles on Business and Human Rights. These frameworks provide clear guidance on conducting robust due diligence, especially focusing on vulnerable groups and areas where exploitation is more likely to occur.

The challenge of insufficient processes

A key challenge is that those complicit in modern slavery thrive on insufficient processes. They exploit weaknesses in systems—gaps in due diligence, compliance, or ethical standards. The risks tied to forced labor and modern slavery aren’t just legal or ethical; they directly impact business operations. Insufficient processes can lead to a culture where poor practices—both environmental and social—are tolerated, ultimately enabling exploitation.

Strategies for the financial sector

One strategy I’d recommend is making modern slavery part of your business reviews and forums. As a financial institution, while we may not manufacture or produce goods, we have a unique position of influence. We can use that influence in key tiers of our supply chain. Whether in Tier 1, where we receive services, or lower down the chain, starting conversations about modern slavery can have a ripple effect. Ask your suppliers about their practices—validate that age checks are conducted, that employees keep their passports, are paid fairly, and aren’t forced to stay at work.

When it comes to validation and assurance, conducting social audits can be challenging, especially as vulnerable groups are often found beyond Tier 1. A simple strategy is to focus on your top ten suppliers by spend. Use your market position to influence those suppliers and understand what they’re doing throughout their supply chains, including with subcontractors.

In conclusion

My main message to the group is to talk about modern slavery, be ambassadors for the issue, and keep it on the agenda. Across all industries, none of us should accept this. Change needs to happen at scale, and that starts by feeling empowered to talk about it and take action.