Create an Anti-Modern-Day Slavery Program

A corporate Anti-Modern-Day Slavery Policy can only be effective if it is implemented within a comprehensive program complemented by training, accountability, and compliance. Corporations should consider developing their own customized Anti-Modern-Day Slavery Corporate Program. Follow Anka’s 9 steps to develop a program:


  1. Understand the Laws: Management must familiarize itself with the laws of the countries where business is conducted and collaborate with local government and law enforcement agencies to combat modern-day slavery.
  2. Review Current Operations: Management must then create an inventory or a list of steps already taken by your company to ensure that your organization, supply chain, and/or subcontractor relationships are not directly or indirectly participating in any activities linked to modern-day slavery.
  3. Set Corporate Goals: Management must set specific and measurable goals for the anti-modern-day slavery program at the beginning so the program can be evaluated in the future. The goals and the amount of effort expended on the program should be in proportion with the resources of the company for the program to have sustainable results. For example, if the company considers itself a leader in its business, it should be an active participant in defining potential slavery issues within its industry through its trade association.
  4. Develop Policy: Management must adopt and develop a clear and concise “zero tolerance” corporate anti-modern-day slavery policy.
  5. Incorporate Policy in Operations: Management must incorporate its anti-modern day-slavery policy in its corporate social responsibility program and codes of ethics and business conduct.
  6. Educate: Management must educate itself, its employees, its stakeholders, its shareholders, and its consumers about modern day slavery issues by building internal and external awareness campaigns to promote the company’s anti-modern-day slavery policy.
  7. Training: Management must make sure all levels of the company are involved in the anti-modern-day slavery program by providing supplemental education and training to all employees including upper management and employees located at the company’s headquarters and if applicable, at its international offices. The focus should be to encourage and motivate everyone to be part of an organization that is making a difference in the fight against human trafficking.
  8. Create Marketing and Branding Campaigns: Management should create marketing and branding promotions to encourage other companies, clients and/or customers to join the fight against modern-day slavery in a way that augments and enhances the company’s brand name value.
  9. Evaluate: Measure and evaluate the specific goals of the anti-modern-day slavery program.

In building their comprehensive Anti-Modern-Day Slavery Program, corporations need to adopt their own customized Anti-Modern-Day Slavery Corporate Policy. The policy will protect the businesses and the victims of slavery. Here are specific reasons as to why businesses need to adopt an Anti-Modern-Day Slavery Corporate Policy:


  1. Adopting an anti-modern-day slavery corporate policy will realize economic and social benefits to your company.
  2. The United States Government has a “zero tolerance” policy regarding trafficking in persons.  There is currently bipartisan support for additional federal and state anti-trafficking legislation in the United States that will impact global and domestic businesses. In addition, forced labor and human trafficking is already illegal globally so businesses should take steps to ensure that their businesses are not contributing in any way to illegal and corrupt activity.
  3. By adopting an anti-modern-day slavery corporate policy and committing to a training and compliance program your company will be taking steps to educate and train your employees about modern day slavery issues. Thus, your company will be in a better position to reduce the risk of litigation, criminal and/or civil investigations and penalties, as well as protecting your company’s image.
  4. Promoting the anti-modern-day slavery policy will improve relations with your company’s stakeholders, shareholders, clients, and customers and will enhance your company’s brand name and reputation.
  5. Promoting the anti-modern-day slavery policy within your organization will increase employee loyalty as they will appreciate the efforts that its employer is engaging in to help eradicate forced labor and human trafficking.
  6. Taking steps to eradicate forced labor and human trafficking is not only the ethical and moral responsibility of all businesses, but it is also the prudent business decision because in the end it positively impacts the bottom line.

Clearly it is smart business and the ethical and moral responsibility of businesses to adopt an anti-modern-day slavery policy.  Here are 8 steps to write an effective policy:


  1. Management needs to determine that an anti-modern-day slavery policy is needed.  Management support is crucial to the implementation of the policy.
  2. Management must select a working group that will be responsible for writing the policy.
  3. The working group must gather information about modern-day slavery and human trafficking.  These individuals must examine the legal framework, definitions of modern-day slavery and human trafficking, and the problems that exist today.
  4. Management and the working group must determine the goal and purpose to be accomplished in writing the policy.
  5. Management and/or the working group must write a clear and concise policy that all employees can easily understand. The policy should include the goals, the definitions, the legal framework, and implementation procedures. There must be enough details in the policy to make the company’s position clear.
  6. Management and/or the working group should review the policy with a select group of employees.  The select group needs to review the policy and provide feedback.
  7. Management and/or the working group should revise the policy based on feedback.  The review and revision process may take multiple cycles in order to incorporate all feedback.
  8. Management should have Anka Rising or legal counsel review the policy and provide feedback.