Desktop Review Audit


Our Approach to your Desktop Review / Audit 

We firstly determine what the entity already does in this space, particularly what existing policies and procedures can be leveraged. A gap analysis will inform next steps and the resources required to eradicate modern slavery from operations and supply chains.

An entity may already have some policies, codes and procedures in place that deal with the commitment to respect human rights and/or deal with modern slavery risks that need updating or extending, or they may need to develop entirely new ones. Policies and procedures should be aligned with international standards and based on the entity’s ethical values and human rights principles.

The first step is to review existing policy documents and codes of conduct to identify if modern slavery-related risks are covered.

Key documents to review when conducting gap analysis include:

  • Supplier code of conduct
  • Supplier contract
  • Human resources policy
  • Procurement policy
  • Whistleblowing & complaints policy and procedures
  • Anti-corruption & fraud policy
  • Human rights policy (including child labour…etc.)
  • Diversity and inclusion policies
  • Employee code of conduct
  • Code of ethics and behaviour
  • Risk appetite statement

Our holistic review of your policies and procedures will not be limited to a desktop examination. We will also engage with the policy owner as well as relevant internal and external stakeholders to understand how it is implemented and understood. For example, there may be a human rights policy that is compliant with international standards but is not implemented in practice, i.e. no one is aware of it or trained on how to execute against it. This analysis will provide a picture of the risk appetite and culture for modern slavery risks within the entity.


Policies can provide guidance for supplier and employee decision-making. They communicate to stakeholders the entity’s stance on modern slavery. Policies on modern slavery need to specify expectations of employees, suppliers, business partners and third parties who are directly linked to the entity’s operations, products and services.

Stakeholders should be engaged during policy development to enable “the entity to hear, understand and respond to their interests and concerns, including through collaborative approaches.”

These policies should be supported and signed off by the board and senior management and distributed across the entity and to affected/relevant stakeholders as well as translated into other languages where applicable.