Supply Chain Assurance: 8 Safety Questions Behind the Statement
Financial services firms and larger technology businesses publish modern slavery statements, run supplier assurance programmes, and answer human capital questions from investors and clients.
Those exercises are usually owned by procurement, legal or sustainability, and they rest on assertions about working conditions in places the organisation has never visited. Health and safety is one of the few functions that knows how to establish whether such assertions are true, and it is rarely asked.
This is not a modern slavery article, and modern slavery obligations should be taken from specialist advice. It is about the safety questions underneath, which are the ones most likely to be answerable and most likely to reveal something.
Eight of them.
1. Where the two exercises actually meet
Start with the overlap, because it is narrower and more useful than "both concern workers".
Section 54 of the Modern Slavery Act 2015 requires certain commercial organisations to publish an annual statement on the steps taken to ensure slavery and human trafficking are not taking place in their business or supply chains, and government guidance sets out what a statement may cover. Those statements routinely describe supplier due diligence, audit programmes and risk assessment.
Safety conditions are one of the more legible indicators available. Hours worked, rest, whether people can refuse unsafe work, whether protective equipment is provided free, and whether there is a functioning route to raise a concern are all things a competent assessor can establish, and all of them appear in labour standards frameworks as well as in health and safety ones.
So the practical position is that your safety function can verify part of what your statement asserts, using methods it already uses.
2. Your own duty reaches their people on your sites
The direct obligation, and it is frequently overlooked because the relationship is commercial.
Section 3 of the Health and Safety at Work etc. Act 1974 requires every employer to conduct its undertaking so that persons not in its employment who may be affected are not exposed to risks. Regulation 11 of the Management Regulations requires employers sharing a workplace to cooperate, coordinate and inform each other of risks.
Cleaners, security, catering, maintenance and IT support staff working in your buildings are covered by that, whoever employs them. A supplier assurance programme that looks only at distant factories and not at the people in your own reception is looking in the wrong direction first.
3. You set the conditions you are assuring against
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The uncomfortable question, and it applies most sharply to outsourced service work.
Where your organisation specifies throughput targets, handle times, shift patterns, staffing ratios or turnaround commitments, you have determined much of the working condition you will later audit.
That is not a reason to avoid the audit. It is a reason to review the specification alongside it. An assurance programme that repeatedly finds excessive hours at a provider whose service levels your own contract sets has diagnosed a commercial decision.
4. What to ask about hours and rest
The most informative area and the most verifiable.
Ask for actual hours worked rather than contracted, for a recent period, by team. Ask how overtime is authorised and recorded, what the position is on consecutive shifts, and how rest is protected where operations run continuously.
This matters more where work is delivered from jurisdictions with prescriptive limits. The Philippines, Colombia, India, Egypt and Brazil all have working time and safety frameworks with their own requirements, and a provider's compliance with them is checkable.
5. What to ask about the right to stop
The question that reveals culture rather than paperwork.
Can a worker decline an unsafe task, end an abusive customer contact, or refuse to enter a space, without seeking permission and without consequence? Is that stated, by whom, and would the workers say the same thing?
Several jurisdictions give this statutory force. Lithuania provides for a right to refuse work where a required health check has not been carried out for reasons outside the employee's control. Latvia attaches a substantial compensation exposure where an employee is forced to resign because safety measures were not taken and the inspectorate confirms it.
6. What to ask about appointments and assessments
The structural questions, and this is where your safety function adds most.
Does the provider hold the appointments its own jurisdiction requires, produced by somebody entitled to produce them? That question has a different answer in almost every country, as covered in our work on jurisdictions that prescribe the author.
A provider in Kenya should be able to show an annual audit by a state-approved advisor with the report filed. One in Bulgaria should have an occupational medicine service contract and an annual declaration. One in Colombia should have a scored self-evaluation. These are verifiable facts rather than assertions.
7. Visit, or at least verify remotely
The step that separates assurance from paperwork.
Questionnaires establish what a provider is willing to state. A visit, a call with workers rather than managers, or an independent review establishes something closer to the position.
Where visiting is disproportionate, independent health and safety audits of key providers, commissioned by you rather than supplied by them, give a materially better basis for what your statement says.
8. Decide in advance what you will do with a finding
The question organisations avoid until it arises.
An assurance programme that produces findings and no consequences trains providers to answer well. One that terminates immediately on any finding encourages concealment and may leave workers worse off.
The workable position is stated in advance: what is a finding requiring a plan and a date, what is a finding requiring escalation, and what is a finding that ends the relationship. Record it, apply it consistently, and keep the evidence, because the record of what you found and did is what supports your statement.
The eight, in short
| Question | Common position | Better position |
|---|---|---|
| The overlap | Two unconnected programmes | Safety verifies part of the statement |
| Your own sites | Distant suppliers only | Section 3 reaches people in your building |
| The specification | Audit findings treated as theirs | Review the contract alongside |
| Hours and rest | Contracted hours | Actual hours, by team, recent |
| Right to stop | Policy stated | Would workers say the same |
| Appointments | Assumed | Verified against national requirements |
| Verification | Questionnaire | Visit or independent audit |
| Findings | Unplanned | Tiered response, decided in advance |
Rows two and three are the ones to act on first. The first is a legal duty owed today, and the second is where an organisation discovers it is auditing the consequences of its own contract.
For international groups
Two considerations.
The comparison point should be local law, not your group standard. A provider meeting its own jurisdiction's requirements may look unfamiliar to a British reviewer while being fully compliant, and a provider matching your group template may be missing a national obligation entirely. The ILO publishes the international standards many national frameworks align to, and government guidance on transparency in supply chains covers the statement itself.
Reporting expectations are converging and moving. Human capital and workforce disclosure requirements have expanded across several jurisdictions in recent years and continue to be revised, so treat the reporting position as something to confirm currently rather than settle once.
Holding provider assessments, findings and actions alongside your own entities in one register is where health and safety consultants and software are worth more together than either alone, and HSE's framework for managing health and safety describes the cycle both your organisation and your providers should sit inside.
Where Arinite fits
Arinite verifies working conditions in places an organisation has not visited, which is the part of supplier assurance that questionnaires cannot do. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years. Our health and safety consultants work extensively with finance and banking, insurance and IT and software organisations, all of which rely heavily on outsourced delivery.
Where providers sit in several countries, our global health and safety consultants establish what each jurisdiction requires of them, and our international health and safety consultants keep that current.
If your organisation publishes a statement about supplier working conditions and nobody from your safety function has ever seen one of those workplaces, a free gap analysis is the right place to start.
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Written by
Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
