Anti-Slavery and Human trafficking Policy Template for India

An Anti-Slavery and Human Trafficking Policy outlines an organization's commitment to preventing forced labor, bonded labor, and trafficking across its operations and supply chains in India. It aligns with key laws like the Bonded Labour System (Abolition) Act 1976 and international standards for worker protection.

The policy requires companies to conduct due diligence, train staff, audit suppliers, and maintain clear reporting systems for violations. It helps businesses demonstrate compliance, protect vulnerable workers, and avoid legal risks while meeting growing expectations from customers and investors for ethical business practices. Most large companies and multinationals operating in India now implement these policies as part of their core governance framework.

Companies operating in India need an Anti-Slavery and Human Trafficking Policy when expanding their supply chains, entering new markets, or working with multiple contractors and vendors. This becomes especially crucial for businesses in manufacturing, construction, agriculture, and textile sectors where labor exploitation risks are higher.

The policy proves vital during supplier onboarding, internal audits, and when responding to investor due diligence requests. It's particularly important when dealing with international clients or partners who require documented commitments to ethical labor practices. Companies bidding for government contracts or seeking ESG certifications also need this policy to demonstrate their compliance with India's labor protection laws.

• Basic Compliance Policy: Focuses on minimum legal requirements under Indian labor laws, suitable for small businesses and startups
• Comprehensive Supply Chain Policy: Includes detailed supplier screening, auditing protocols, and remediation procedures for large manufacturers
• Service Industry Policy: Tailored for IT, hospitality, and consulting firms, emphasizing staff training and third-party contractor management
• Multi-national Framework: Combines international standards with Indian regulations, ideal for companies operating globally
• Sector-specific Policy: Contains industry-specific risk assessments and prevention measures for high-risk sectors like construction and textiles

• Corporate Legal Teams: Draft and update the Anti-Slavery Policy, ensure compliance with Indian labor laws, and coordinate with external counsel
• HR Departments: Implement policy guidelines, conduct employee training, and maintain reporting mechanisms
• Supply Chain Managers: Screen suppliers, conduct audits, and ensure vendor compliance with policy requirements
• Board of Directors: Approve and oversee policy implementation, review compliance reports, and manage reputational risks
• External Stakeholders: Investors, customers, and regulators who require evidence of ethical labor practices and compliance
• Suppliers and Contractors: Must adhere to policy requirements and undergo regular audits to maintain business relationships

• Supply Chain Mapping: Document all suppliers, contractors, and business partners across your operations in India
• Risk Assessment: Identify high-risk areas in your operations, particularly in manufacturing, construction, or agriculture
• Legal Requirements: Review current Indian labor laws, including the Bonded Labour Act and trafficking regulations
• Industry Standards: Research sector-specific best practices and compliance frameworks
• Reporting Mechanisms: Design clear procedures for reporting violations and protecting whistleblowers
• Training Plans: Outline staff training requirements and awareness programs
• Audit Procedures: Develop supplier audit checklists and assessment criteria

• Policy Statement: Clear commitment to preventing modern slavery and human trafficking in operations
• Legal Framework: Reference to Indian labor laws, Bonded Labour Act, and international conventions
• Scope Definition: Coverage across company operations, subsidiaries, and supply chain partners
• Due Diligence Process: Supplier assessment criteria and verification procedures
• Reporting Mechanism: Confidential reporting channels and whistleblower protection measures
• Training Requirements: Mandatory staff awareness programs and documentation
• Enforcement Provisions: Consequences for non-compliance and remediation procedures
• Review Schedule: Annual policy review and update requirements

An Anti-Slavery and Human Trafficking Policy is often confused with a Compliance and Ethics Policy, but they serve distinct purposes in India's legal framework. While both address ethical business conduct, their scope and implementation differ significantly.

• Focus and Scope: Anti-slavery policies specifically target forced labor and trafficking risks in supply chains, while Compliance and Ethics policies cover broader ethical business practices including corruption, discrimination, and general misconduct
• Legal Requirements: Anti-slavery policies directly align with India's Bonded Labour Act and trafficking laws, whereas Compliance and Ethics policies address multiple regulatory frameworks including Companies Act compliance
• Implementation: Anti-slavery policies require specific supplier audits and worker protection mechanisms, while Compliance and Ethics policies typically focus on internal conduct and corporate governance
• Stakeholder Impact: Anti-slavery policies primarily affect supply chain partners and labor contractors, while Compliance and Ethics policies govern all employees and business relationships