Modern Slavery Risk Assessment for United Arab Emirates

Modern Slavery Risk Assessment Template for United Arab Emirates

A comprehensive template designed for organizations operating in the United Arab Emirates to assess and document their exposure to modern slavery risks in accordance with UAE Federal Law No. 51 of 2006 on Combating Human Trafficking Crimes and related legislation. This document provides a structured framework for evaluating risks across operations and supply chains, incorporating UAE-specific legal requirements while aligning with international best practices. It includes detailed assessment criteria, risk matrices, and action planning tools to help organizations identify, assess, and mitigate modern slavery risks in their business activities.

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What is a Modern Slavery Risk Assessment?

The Modern Slavery Risk Assessment Template has been developed to help organizations operating in the UAE comply with their obligations under Federal Law No. 51 of 2006 and related legislation while implementing effective risk management practices. This document is essential for organizations seeking to identify and address modern slavery risks in their operations and supply chains, particularly in light of increasing global scrutiny and regulatory requirements. It incorporates UAE-specific legal requirements, international best practices, and practical guidance for risk assessment and mitigation. The template should be used periodically (typically annually) to assess current risks, evaluate the effectiveness of existing controls, and develop action plans for improvement. It is particularly valuable for organizations with complex supply chains, international operations, or activities in high-risk sectors.

What sections should be included in a Modern Slavery Risk Assessment?

1. 1. Document Control: Version number, date of assessment, review date, and approval details

2. 2. Organization Overview: Basic information about the organization, including size, sector, and operational footprint

3. 3. Scope of Assessment: Details of what business units, geographical locations, and supply chain tiers are covered by the assessment

4. 4. Risk Assessment Methodology: Explanation of the risk assessment approach, scoring criteria, and evaluation methods used

5. 5. Supply Chain Mapping: Identification and categorization of suppliers, contractors, and business partners

6. 6. Country Risk Analysis: Assessment of modern slavery risks in countries of operation and sourcing

7. 7. Industry/Sector Risk Analysis: Evaluation of risks specific to relevant industries and sectors

8. 8. Workforce Risk Assessment: Analysis of risks related to employment practices, recruitment, and labor conditions

9. 9. Control Measures: Current policies, procedures, and practices to prevent modern slavery

10. 10. Gap Analysis: Identification of areas where current controls may be insufficient

11. 11. Action Plan: Detailed plan for addressing identified risks and gaps

12. 12. Monitoring and Review: Process for ongoing monitoring and periodic review of risk assessment

What sections are optional to include in a Modern Slavery Risk Assessment?

1. Supplier Due Diligence Process: Detailed supplier assessment procedures - recommended for organizations with complex supply chains

2. Industry Benchmarking: Comparison with industry standards and peer practices - useful for larger organizations

3. Stakeholder Engagement: Details of consultation with workers, unions, and other stakeholders - recommended for organizations with significant workforce

4. Training and Awareness: Overview of training programs and awareness initiatives - optional for smaller organizations

5. Grievance Mechanisms: Description of reporting and remediation processes - recommended for organizations with direct employment

6. Risk Assessment for Special Projects: Additional assessment for major projects or new ventures - useful for project-based organizations

What schedules should be included in a Modern Slavery Risk Assessment?

1. Schedule 1: Risk Assessment Matrix: Detailed risk scoring matrix and evaluation criteria

2. Schedule 2: Supplier Questionnaire Template: Standard questionnaire for gathering information from suppliers

3. Schedule 3: Country Risk Indicators: List of indicators and data sources for country risk assessment

4. Schedule 4: Control Measures Checklist: Comprehensive checklist of potential control measures

5. Appendix A: Relevant Legislation Summary: Summary of applicable UAE and international laws

6. Appendix B: Red Flag Indicators: List of warning signs and indicators of modern slavery

7. Appendix C: Useful Resources and Contacts: List of organizations, helplines, and support services

8. Appendix D: Document Templates: Supporting templates for implementation (e.g., supplier codes of conduct, audit checklists)

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions
Clauses
Relevant Industries

Construction

Manufacturing

Retail

Hospitality

Transportation and Logistics

Agriculture

Textile and Apparel

Oil and Gas

Mining

Electronics

Food and Beverage

Healthcare

Facilities Management

Real Estate Development

Professional Services

Relevant Teams

Legal

Compliance

Procurement

Supply Chain

Human Resources

Risk Management

Internal Audit

Corporate Social Responsibility

Operations

Health and Safety

Ethics and Governance

Sustainability

Relevant Roles

Chief Compliance Officer

Risk Manager

Head of Procurement

Supply Chain Director

Human Resources Director

Legal Counsel

Sustainability Manager

Ethics Officer

Operations Director

Audit Manager

Corporate Social Responsibility Manager

Health and Safety Manager

Procurement Officer

Supplier Relationship Manager

Compliance Analyst

Due Diligence Specialist

Industries
UAE Federal Law No. 51 of 2006 on Combating Human Trafficking Crimes (as amended): The primary anti-trafficking legislation in the UAE that criminalizes all forms of human trafficking and provides the framework for prevention, prosecution, and victim protection
UAE Federal Law No. 8 of 1980 (UAE Labor Law): Regulates labor relations and establishes fundamental rights of workers, including provisions against forced labor, working hours, and fair treatment
Federal Law No. 10 of 2017 on Domestic Workers: Specific legislation protecting domestic workers' rights, including working hours, contracts, and proper treatment, as this group is particularly vulnerable to modern slavery
UAE Federal Law No. 3 of 1987 (Penal Code): Contains provisions criminalizing various forms of exploitation and abuse that could constitute modern slavery
UN Protocol to Prevent, Suppress and Punish Trafficking in Persons (Palermo Protocol): International treaty ratified by UAE that provides the international framework for combating human trafficking
ILO Forced Labour Convention (No. 29): International convention ratified by UAE that defines and prohibits forced labor
UAE Federal Law No. 1 of 2015 on Commercial Companies: Includes corporate governance requirements and responsibilities that could extend to ensuring supply chains are free from modern slavery
UAE Cabinet Resolution No. 40 of 2019 on Administrative Fines: Determines fines for violations of labor laws and regulations, including those related to worker exploitation
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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