Anti-Slavery and Human trafficking Policy Template for Nigeria

An Anti-Slavery and Human trafficking Policy outlines an organization's commitment and steps to prevent modern slavery practices in its operations and supply chains. In Nigeria, this policy helps companies comply with the Trafficking in Persons Law Enforcement and Administration Act while protecting vulnerable workers from exploitation, forced labor, and trafficking.

The policy requires businesses to conduct due diligence on suppliers, train staff to spot warning signs, and establish clear reporting channels for concerns. It's particularly important for Nigerian companies working in high-risk sectors like manufacturing, agriculture, and construction, where they must demonstrate active measures to prevent modern slavery and support national anti-trafficking efforts.

Companies operating in Nigeria need an Anti-Slavery and Human trafficking Policy when expanding their supplier network, entering new markets, or working with international partners. This policy becomes essential for businesses in high-risk sectors like agriculture, construction, and manufacturing, where labor exploitation risks are significant.

The policy proves particularly valuable during government audits, when bidding on major contracts, or establishing relationships with multinational corporations that require strong anti-trafficking commitments. It's crucial for companies with complex supply chains, multiple contractors, or operations in regions where forced labor has been reported. Nigerian businesses also need this policy to maintain compliance with the Trafficking in Persons Act and protect their reputation.

• Basic Compliance Policy: Core anti-slavery requirements for smaller Nigerian businesses, focusing on local law compliance and basic reporting procedures
• Comprehensive Corporate Policy: Detailed version for large organizations, including supply chain monitoring, training programs, and international standards alignment
• Industry-Specific Policy: Tailored for high-risk sectors like agriculture or construction, with specific risk assessments and control measures
• Multinational Adaptation: Enhanced version meeting both Nigerian and international requirements, suitable for companies with global operations
• SME-Focused Policy: Simplified format for small/medium enterprises, emphasizing practical implementation steps and cost-effective compliance measures

• Corporate Legal Teams: Draft and update the Anti-Slavery Policy, ensuring compliance with Nigerian labor laws and international standards
• Board Members: Review and approve the policy, setting the tone for organizational commitment to anti-trafficking measures
• HR Managers: Implement policy guidelines, conduct staff training, and maintain reporting mechanisms
• Supply Chain Directors: Monitor supplier compliance and conduct due diligence on new business partners
• Compliance Officers: Oversee policy enforcement, investigate violations, and coordinate with regulatory authorities
• Department Heads: Ensure their teams understand and follow policy requirements in daily operations

• Supply Chain Review: Map your complete supply network, identifying high-risk areas and existing supplier relationships
• Legal Requirements: Review Nigeria's Trafficking in Persons Act and relevant international standards
• Risk Assessment: Document industry-specific slavery risks, vulnerable worker groups, and geographical risk factors
• Internal Processes: List existing recruitment, contracting, and monitoring procedures
• Training Needs: Identify key staff requiring anti-slavery awareness training
• Reporting Mechanisms: Plan clear channels for reporting concerns and violations
• Enforcement Strategy: Outline investigation procedures and consequences for non-compliance

• Policy Statement: Clear commitment to zero tolerance for modern slavery and human trafficking
• Scope Definition: Details of covered operations, subsidiaries, and supply chain relationships
• Legal Framework: Reference to Nigerian Trafficking in Persons Act and relevant international laws
• Due Diligence Procedures: Specific steps for supplier assessment and monitoring
• Reporting Mechanisms: Confidential channels for raising concerns and whistleblower protection
• Training Requirements: Mandatory staff awareness and compliance training schedules
• Enforcement Measures: Consequences for violations and remediation procedures
• Review Process: Annual policy evaluation and update requirements

While both an Anti-Slavery and Human trafficking Policy and a Compliance and Ethics Policy address organizational conduct, they serve distinct purposes in Nigerian business operations. The Anti-Slavery policy specifically targets modern slavery risks and human trafficking prevention, while a Compliance and Ethics Policy covers broader ethical business practices.

• Scope of Coverage: Anti-Slavery policies focus exclusively on forced labor and trafficking issues, while Compliance and Ethics policies address multiple areas including corruption, conflicts of interest, and general business conduct
• Legal Requirements: Anti-Slavery policies directly align with the Trafficking in Persons Act, while Compliance and Ethics policies respond to various Nigerian corporate governance laws
• Implementation Focus: Anti-Slavery policies emphasize supply chain monitoring and worker protection, whereas Compliance and Ethics policies prioritize overall corporate behavior and culture
• Reporting Mechanisms: Anti-Slavery policies require specific trafficking-related reporting channels, while Compliance and Ethics policies establish broader whistleblowing systems