Anti-Slavery and Human trafficking Policy Template for Netherlands

An Anti-Slavery and Human trafficking Policy outlines how organizations actively prevent modern slavery and exploitation in their operations and supply chains. Under Dutch law, particularly the Criminal Code Article 273f, companies must take steps to identify and stop forced labor, trafficking, and other forms of modern slavery.

The policy sets clear rules for employee conduct, supplier screening, and reporting concerns. It typically includes due diligence procedures, risk assessments, and training requirements to help staff spot warning signs. Dutch businesses use these policies to protect workers' rights and comply with both national laws and international standards like the EU Anti-Trafficking Directive.

Dutch companies need an Anti-Slavery and Human trafficking Policy when expanding their supply chains internationally or working with new suppliers, especially in high-risk sectors like textiles, agriculture, or construction. It becomes essential when your organization has more than 50 employees or annual revenue exceeding €40 million, as these factors increase exposure to trafficking risks.

The policy proves particularly valuable during supplier audits, merger due diligence, or when bidding on government contracts. Dutch authorities often require evidence of anti-trafficking measures during investigations or compliance checks. Having this policy in place helps protect your organization from legal penalties and reputational damage while demonstrating commitment to ethical business practices.

• Basic Policy: Core anti-trafficking commitments, reporting procedures, and supplier screening requirements - suitable for small to medium enterprises
• Comprehensive Corporate Policy: Detailed risk assessments, due diligence protocols, and global supply chain monitoring - ideal for multinational companies
• Sector-Specific Policy: Tailored measures for high-risk industries like construction, agriculture, or manufacturing, with industry-specific red flags
• Supply Chain Focus: Emphasizes supplier vetting, auditing procedures, and contractual requirements for business partners
• Integrated Policy: Combines anti-trafficking measures with broader human rights and ethical trading commitments

• Corporate Legal Teams: Draft and update the Anti-Slavery Policy, ensuring compliance with Dutch and EU regulations
• Board Members: Review and approve the policy, setting the tone for ethical business practices
• HR Managers: Implement training programs and handle internal reporting procedures
• Procurement Officers: Screen suppliers and enforce policy requirements throughout the supply chain
• Compliance Officers: Monitor adherence, conduct audits, and report to management
• Suppliers and Contractors: Must comply with policy requirements as part of business agreements
• Employees: Follow guidelines and report potential violations through designated channels

• Supply Chain Map: Document all suppliers, subcontractors, and high-risk business relationships
• Risk Assessment: Identify vulnerable areas in operations and supply chains, focusing on sector-specific risks
• Legal Requirements: Review Dutch Criminal Code Article 273f and EU anti-trafficking directives
• Reporting Mechanisms: Set up clear procedures for reporting concerns and protecting whistleblowers
• Training Needs: Plan staff awareness programs and specific training for high-risk roles
• Due Diligence Process: Establish supplier screening and monitoring procedures
• Implementation Plan: Create timeline for policy rollout, training, and compliance checks

• Policy Statement: Clear commitment to preventing modern slavery and human trafficking
• Scope Definition: Specify coverage across operations, subsidiaries, and supply chains
• Legal Framework: Reference to Dutch Criminal Code Article 273f and relevant EU directives
• Due Diligence Procedures: Detailed supplier assessment and monitoring protocols
• Reporting Mechanisms: Confidential reporting channels and whistleblower protection measures
• Training Requirements: Mandatory staff awareness and role-specific training programs
• Enforcement Measures: Consequences for non-compliance and remedial actions
• Review Process: Annual policy review and update procedures

The Anti-Slavery and Human trafficking Policy is often confused with the Compliance and Ethics Policy, but they serve distinct purposes in Dutch corporate governance. While both address ethical business conduct, their scope and focus differ significantly.

• Focus and Scope: Anti-Slavery policies specifically target modern slavery and human trafficking risks, while Compliance and Ethics policies cover broader ethical standards and regulatory compliance
• Legal Requirements: Anti-Slavery policies directly address Dutch Criminal Code Article 273f requirements, whereas Compliance and Ethics policies encompass multiple regulatory frameworks
• Supply Chain Impact: Anti-Slavery policies include specific supplier screening and monitoring protocols, while Compliance and Ethics policies typically focus on internal conduct
• Reporting Mechanisms: Anti-Slavery policies require specialized trafficking-related reporting channels, compared to the general misconduct reporting in Compliance policies
• Training Focus: Anti-Slavery policies mandate specific training on trafficking indicators, while Compliance policies cover broader ethical decision-making