Showing posts with label Modern Slavery Act 2015. Show all posts
Showing posts with label Modern Slavery Act 2015. Show all posts

Friday, 10 March 2017

Is there a lesson for procurement in Tory's forgotten manifesto?

The suggestion that the Chancellor's advisors simply "forgot the manifesto"  may well be a symptom of incompetence or just contempt for previous commitments but it does have lessons for procurement leaders.  First let's think about the purpose of a manifesto - it sets out the basis on which the political party seeks election and says "if you elect us, we'll do this".  It is a bit like a contract commitment with the electorate. It is a commitment, through choice, to pursue a particular strategy. Simply 'forgetting' that policy commitment and strategy is a serious breach of trust.

So what's the 'forgetting the manifesto' lesson for procurement? Well, I have long since stopped being surprised when I find out that procurement staff are oblivious to the higher-level policies, and even their own prior commitments, which are supposed to shape their decisions.  For example, a commitment that all staff complete anti-bribery training - when you ask the staff when they last completed it they were unaware of such a commitment.  Then there's the Fairtrade commitments, the sustainable procurement commitments, prompt payment commitments, .... need I go on? Breach of all these 'policy' commitments represents a reputational risk at the very least.  Let's face it the commitments are rarely made without a lot of deliberation and business case justification.

Many of those commitments are voluntary but there are also statutory commitments - surprisingly there appears to be little external policing of those, for example, the Equality Act, Modern Slavery Act and Bribery Act.

Strange thing is when you interview staff for a position, quite frequently they can trot out all the relevant commitments!

Is this a case of selective memory or perhaps just ignorance? Both could be factors but they are unlikely to be the only causes.

My suggestion to ensure there is no 'forgetting' is that:
  1. Complete an audit to identify and catalogue external and internal commitments;
  2. Embed within risk management, yes, even at the top table;
  3. Raise awareness; 
  4. Ensure no commitments are overlooked through the use of checklists for both strategy and tactical decisions. 
The UK Prime Minister and Chancellor of the Exchequer now appear to have to backtrack due to 'forgetting the manifesto' - surely there's a lesson for procurement risk management to make sure there isn't a similar carryover in your organisation.

Monday, 26 December 2016

It's time for a review of the impact of procurement legislation

Today The Times reported that the Ministry of Defence takes bribery and corruption very seriously and has made dozens of allegations about bribery and corruption in supply chains.   Now, I ask you, which organisation is going to admit it doesn't take bribery and corruption seriously?

However, often when I meet with 'procurement leaders' and make reference to the Modern Slavery Act, and/or the Bribery Act, I don't get the impression either of those pieces of legislation are taken that seriously at all. Indeed, I am often left with feeling nothing is really happening there.

Perhaps, as a profession, it is time to take stock and ask what difference these types of legislation actually have on the procurement community.  Are we fooling ourselves?

Surely if the profession is committed to the spirit of the legislation it would make sense to lead an impact assessment to establish 'so what?'.  Commitment to the spirit of the legislation isn't enough.  I suggest we need performance management, and yes, sanctions on those within the profession - I have to think long and hard to recall any 'naming, shaming and being struck off' - are we fooling ourselves that all is rosy.

Wednesday, 29 July 2015

Child labour and talk are too cheap - meaningful action is what counts.

David Cameron is using a platform in Vietnam today to announce the UK's initiative to stamp out child labour in supply chains. Don't get me wrong, I find child labour absolutely abhorrent and really do believe in the power of responsible procurement. However, I doubt Cameron's initiative to stamp out child labour, based on all companies with a turnover of over £36m publishing an annual slavery and human trafficking statement, will have any significant impact.

Does David Cameron actually believe that companies have that sort of supply chain visibility or even the skills? Does the public sector have that sort of visibility and skills?

The initiative will require companies to declare what checks they have in place. What would be considered acceptable robust checks? Will Cameron's minister who leads on public procurement be in a position to be accountable to parliament and the electorate for the steps public procurement have taken - if not it is a bit hypocritical to not to lead by example. Perhaps Cameron should add this to his wish-list of EU reforms - that will be popular but then isn't cutting red tape a big issue too!

How is the initiative going to be communicated to UK companies? August is unlikely to be the best time to raise awareness.

In companies which do become aware of the initiative who will have ownership and be accountable? Will it be allocated to the Health & Safety Officer like so much of environmental purchasing, the CFO as part of their accounting statements, the CPO who control so little of the budget decisions, marketing who will want to put a good gloss on whatever the reality is, or the risk manager who is often a voice crying in the wilderness? Whoever holds responsibility will be a good indicator of how seriously the initiative is taken - why doesn't Cameron insist there's a named responsible owner?

I assume the statement will need to be audited in some form, who will do that?

What if the companies don't comply? It appears the sanction is criticism! Is that supposed to be a serious sanction? I have previously discussed reputational risk linked with supply chain abuses and how it really doesn't seem to manifest itself  in the market. I have also questioned the conviction of politicians to see some of these great ideas through to the end rather than just looking for something to say in a speech.

So, do I expect to see some discernible change in five years against today's benchmark? Actually is there a benchmark against which progress will be measured?

PS 31 July 2015 - here's a link to the relevant section of the Modern Slavery Act 2015