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Responding to the NSW Anti-slavery Commissioner’s Guidance on Reasonable Steps

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Responding to the NSW Anti-slavery Commissioner’s Guidance on Reasonable Steps

In December 2023, the NSW Anti-slavery Commissioner released his Guidance on Reasonable Steps (GRS) to manage modern slavery risks in operations and supply chains.

The GRS came into effect on 1 January 2024. It sets out the main issues and concepts to be understood to meet reporting and due diligence expectations (i.e undertake ‘reasonable steps’) under NSW modern slavery legislation.

The GRS includes the following seven steps:
  1. Commit
  2. Plan
  3. Source
  4. Manage
  5. Remedy
  6. Report
  7. Improve

You can access the GRS and find out more here.

How can LGP help councils meet the GRS requirements?

LGP has been working since 2018 to raise awareness of modern slavery amongst both councils and contractors. Through a number of initiatives, we have been assisting councils to identify, assess and reduce the risk of modern slavery in their supply chains. These initiatives, which assist councils in responding to the GRS, include:

  • Annual modern slavery risk assessment of LGP approved contractors

LGP undertakes an annual modern slavery risk assessment across all its panel contracts (in November/December). Using the outcome of the assessment, all approved contractors are assigned a modern slavery risk rating of either low, moderate or high. These risk ratings are displayed as Supplier Intelligence (SI) badges in VendorPanel and can be seen when creating an RFx under an LGP Contract. Use of these risk ratings means that the process of distributing, collecting and assessing modern slavery questionnaires from suppliers has already been done for you.

The SI badges can assist councils in meeting GRS steps 3 & 4.

 

  • Modern slavery risk assessment of council suppliers

Based on our developed and tested methodology used to risk assess LGP approved contractors, we can perform a modern slavery risk assessment for councils, very cost-effectively.

A modern slavery risk assessment of a council’s contractors can assist the council in meeting GRS steps 3 & 4.

 

  • Modern Slavery Toolkit for councils

We have developed an online Modern Slavery Toolkit that provides resources to assist councils to identify, assess and manage modern slavery risks.

All toolkit resources are aligned with the GRS, and future resources will be added to further complement the Guidance.

A recent addition to the toolkit is a flowchart of the GRS ‘Reasonable Steps’, that identifies resources (from LGP or elsewhere) that are available to assist in meeting each of those steps.

LGP’s Modern Slavery Toolkit for councils can assist councils in meeting all 7 GRS steps.

 

  • Modern Slavery Awareness Training

LGP can deliver Modern Slavery Awareness Training to councils. This training can be tailored to include specific content relating to what your council is doing to detect and prevent slavery in Council’s supply chain and any obligations/requirements relating to staff.

We can also provide Modern Slavery Awareness Training to your contractors.

LGP’s Modern Slavery Awareness Training can assist councils in meeting GRS steps 4 & 7.

 

  • Modern Slavery Toolkit for SMEs

LGP has developed an online Modern Slavery Toolkit to assist small and medium-sized enterprises (SMEs). It provides resources to assist your SME contractors to identify, assess and manage modern slavery risks.

LGP’s Modern Slavery Toolkit for SMEs can assist councils in meeting GRS step 4.

 

If you need assistance with the above or you would like a quote for us to embed Modern Slavery into your council, contact us via email.

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