Warning signs of unethical practice and social deprivation

Here are some of the warning signs that may indicate unethical practices are taking place: 

1. Higher-than expected return on investment.
2. Response times that are far better than you would expect.
3. Frequent changes in personnel.
4. Reluctance to let other people help with your work.
5. Lifestyle that is not matched to known income.
6. Suspicious management of information and reluctance to share.
7. Dislike of auditing activities.
8. No recording of communications via email.

How to prevent poor practice:

Planning: react quickly when issues are identified and involve senior management. If the problem cannot be resolved, you may need to end the  relationship with a supplier. If this happens, check that your supplier’s employees have been/will be paid before you make any final payments.

Policies should be in place to prevent, detect and eradicate modern slavery within your own operations and the operations of suppliers. Codes of conduct should set out expected standards of behaviour; contracts should explicitly refer to modern slavery. Encourage whistle blowing to identify breaches of policy and contractual provisions.

Have processes  to identify risks and vulnerabilities. You cannot always audit and monitor the entire supply chain at all levels. But businesses should be able to identify key vulnerabilities and take a risk management approach to ethical procurement. Contracts should include supplier and contractor performance targets or sanctions for non-compliance.

Possible breaches of a Code of Ethics include:  

• Not disclosing a conflict of interest
• Breaking confidentiality
• Not paying a fair salary
• Not providing healthy and safe working conditions
• Accepting bribes

Have a response plan for specific situations where fraud or corruption are identified. Make a commitment to act decisively. 

• Explain how suspicions of fraud should be reported. Is there a phone number for whistle blowers?
• Describe steps the organisation will take to fully investigate allegations.
• List the people/roles that will be involved in the response.
• Detail any sanctions and/or remedy a situation that may apply in the event the allegation is proven.
• Share the plan with your workforce, together with the consequences of not complying with company policy on fraud bribery, corruption and unethical behaviour.