A recent campaign against modern slavery in London has attracted huge public support, including from Priti Patel, the secretary of state for international development, who has pledged to commit millions of pounds to tackle the problems exposed by the Evening Standard investigation.
The Modern Slavery Act 2015 (MSA) contains three key criminal offences: slavery, servitude and forced or compulsory labour; human trafficking; and committing an offence with the intention to commit human trafficking.
The act also creates transparency in supply obligation that applies to commercial organisations in any sector that supply goods or services, carry on a business or part of a business in the UK, and have an annual turnover of more than £36 million.
Organisations have to prepare a slavery and human trafficking statement each financial year. The statement may include: the organisation’s structure, its business and supply chains; policies in relation to slavery and human trafficking, and training available for staff; the due diligence processes in relation to slavery and human trafficking in its business and supply chains; the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk.
According to a recent survey by the Chartered Institute of Procurement & Supply, one in ten UK supply chain managers has found evidence of modern slavery in their supply chains since the MSA came into force. The survey also revealed that, of those required to complete a statement, a third of British companies have not, while almost two thirds of foreign companies have failed to comply.
A recent study of 50 big-name brands by Core, a corporate accountability watchdog, found that many indicated that they were short on detail and lacked transparency in a mandatory annual statement under the MSA, with five appearing not to have filed a statement. “The level of compliance is disappointing: since the government has positioned itself as a leader on modern slavery, there has to be more action in sanctioning companies for not reporting,” said Marilyn Croser, Core’s director.
The Modern Slavery (Transparency in Supply Chains) Bill 2017 seeks to amend the MSA to make further provision for transparency in supply chains by clarifying what must be included in the statement, forcing organisations to provide reasons for failing to take steps to eradicate human trafficking and slavery, publishing a list of all of those required to publish a transparency statement and banning those who fail to comply from participating in public procurement.
Reputational damage can be irreversible. The onus is very firmly on companies to reassure the public of their integrity, the integrity of their products and of their support of the international effort to eradicate modern slavery.
This article was originally published in The Times and can be accessed here, behind a paywall.
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