New UK modern slavery consultation: transparency in supply chains

Posted: 23/07/2019

July 2019 saw the UK Government commit to strengthening section 54 (transparency in supply chains requirements) of the Modern Slavery Act 2015 (MSA) with the launch of a new consultation. The Government’s aim is to ensure a level playing field for responsible businesses by recognising their effective anti-slavery activity and commitment to improve, but also by targeting non-compliance and further embedding the reporting requirements.

The consultation focuses on three main areas:

Content of statements

Currently section 54 of MSA provides that the statement ‘may’ report on six areas. The consultation indicates that the Government is considering making reporting on these areas compulsory to encourage comprehensive submissions and prioritised action, as well as aiding external scrutiny by bringing more consistency to reporting.

The consultation points out that in 2018 the Business & Human Rights Resource Centre disclosed that whilst 41% of the FTSE 100 reported on their slavery and trafficking policies, only 17% reported on effectiveness, highlighting inconsistency across the specified areas and a lack of uptake in voluntarily covering the Home Office’s suggested content.

Transparency, compliance and enforcement

The consultation confirms the Government’s proposal to both develop an online registry for published modern slavery statements, and amend the legislation to mandate publication of this registry. The centralised registry will increase the accessibility of statements to enable greater scrutiny and comparison of the action being taken by both similar and contrasting  organisations.

The consultation also proposes the introduction of a single reporting deadline on which all organisations must publish their statement each year. Consideration is given to whether the introduction of civil penalties could be an effective tool to increase compliance with the requirement to publish a modern slavery statement, and if so, what a proportionate approach to enforcement would be.

Public sector supply chains

The Government has proposed that the reporting requirement is extended to capture a wide range of public bodies, which have a budget of £36 million or more, unless they are already captured by the existing legislation.

It aims to collaborate with international partners to create incentives for businesses to increase their ambition and accelerate progress towards ending modern slavery by 2030. 

Consequently, the consultation, which runs from 9 July 2019 – 17 September 2019 inclusive, should be reviewed carefully, as around 17,000 UK businesses will be required to report. Full details and an online form can be found on the Government website.

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