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An Anti-Slavery and Human Trafficking Policy outlines a company's commitment and actions to prevent modern slavery in its operations and supply chains, as required by German and EU labor laws. It sets clear rules about forced labor, exploitation, and human trafficking while explaining how the organization identifies and addresses these risks.

Under this policy, businesses must conduct due diligence checks on suppliers, train staff to spot warning signs, and establish reporting procedures for concerns. It aligns with Germany's Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz) and helps companies protect vulnerable workers while avoiding legal penalties and reputational damage.

Companies operating in Germany need an Anti-Slavery and Human Trafficking Policy when they have 3,000 or more employees, or when they work with international suppliers. This requirement becomes especially urgent when expanding into new markets, changing suppliers, or facing increased scrutiny from stakeholders about supply chain ethics.

The policy proves essential during supplier audits, employee training sessions, and when demonstrating compliance with the Supply Chain Due Diligence Act. It's particularly valuable when bidding on government contracts, pursuing ESG certifications, or responding to investor due diligence requests about human rights practices in your supply chain.

• Basic Compliance Policy: Covers minimum legal requirements under German law, focusing on direct operations and first-tier suppliers
• Comprehensive Supply Chain Policy: Extends oversight across entire supply networks, including detailed supplier assessment procedures
• Industry-Specific Policies: Tailored for high-risk sectors like textiles, manufacturing, or agriculture with sector-specific controls
• SME-Adapted Policy: Simplified version for smaller businesses below the 3,000-employee threshold who voluntarily implement controls
• Global Operations Policy: Enhanced version incorporating international standards alongside German requirements for multinational companies

• Legal Department: Drafts and updates the Anti-Slavery Policy to meet German legal requirements
• Board of Directors: Reviews and approves the policy, ensuring corporate commitment
• Compliance Officers: Monitor implementation and conduct regular audits
• HR Managers: Train employees and integrate policy requirements into hiring practices
• Procurement Teams: Screen suppliers and ensure supply chain compliance
• Employees: Follow policy guidelines and report concerns through designated channels
• Suppliers and Contractors: Must adhere to policy standards when working with the company

• Supply Chain Map: Document all suppliers, subcontractors, and their locations
• Risk Assessment: Identify high-risk areas in operations and supply chains
• Legal Requirements: Review the Supply Chain Due Diligence Act and EU regulations
• Internal Processes: Map existing procurement and supplier screening procedures
• Training Needs: Determine who needs training and what type
• Reporting Systems: Set up confidential channels for raising concerns
• Implementation Plan: Create timeline for policy rollout and staff training
• Review Mechanism: Establish regular audit and update schedule

• Policy Statement: Clear commitment to preventing modern slavery and human trafficking
• Scope Definition: Outline of covered operations, suppliers, and geographical regions
• Due Diligence Procedures: Detailed supplier assessment and monitoring processes
• Risk Assessment Framework: Methods for identifying and evaluating potential violations
• Reporting Mechanisms: Confidential whistleblowing procedures and protection measures
• Training Requirements: Mandatory staff education and awareness programs
• Enforcement Measures: Consequences for non-compliance and remediation steps
• Review Process: Annual policy evaluation and update procedures

While an Anti-Slavery and Human Trafficking Policy and a Compliance and Ethics Policy may seem similar, they serve distinct purposes in German business operations. The main differences lie in their scope, focus, and legal requirements.

• Scope of Coverage: Anti-Slavery policies specifically target forced labor and human trafficking risks in supply chains, while Compliance and Ethics policies cover broader ethical business conduct including corruption, fraud, and general regulatory compliance
• Legal Framework: Anti-Slavery policies directly respond to the Supply Chain Due Diligence Act requirements, whereas Compliance and Ethics policies address multiple German and EU regulations
• Implementation Requirements: Anti-Slavery policies mandate specific supply chain monitoring and reporting procedures, while Compliance and Ethics policies focus on internal conduct and general business practices
• Stakeholder Focus: Anti-Slavery policies primarily target supplier relationships and external operations, while Compliance and Ethics policies primarily govern internal employee behavior and corporate culture