Modern slavery statements: Independent Review recommends steps for improving quality and increasing compliance
An Independent Review of the law on modern slavery has recommended changes to improve the quality of modern slavery statements and increase compliance.
The Independent Review recommends changes to the law so that:
- Companies are not able to state that they have taken no steps to address modern slavery in their supply chains
- Companies must report on the six areas which guidance currently recommends they report on (see below)
- Companies must refer to their modern slavery statement in their annual report
- Failure to meet modern slavery reporting requirements becomes an offence which can lead to a director’s disqualification
The Review also recommends that:
- There should be a central repository for modern slavery statements
- There should be fines and other sanctions for non-compliance and a new enforcement body
- Public sector organisations should also have to publish modern slavery statements.
The government is now considering the Review's recommendations and will respond in due course.
What does the law say?
The Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a turnover of £36m or more to publish a modern slavery statement for each financial year. The statement should set out the steps they have taken to ensure that their business and supply chains are slavery free, or confirm that they have taken no steps to do this. The Act indicates that a statement may contain information about
- the organisation’s structure, its business and its supply chains
- the organisation’s policies in relation to slavery and human trafficking
- the organisation’s due diligence processes in its business and supply chains
- the parts of the organisation’s business and supply chains where there is a risk of slavery and human trafficking and the steps taken to assess and manage that risk
- the organisation’s effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against appropriate performance indicators
- training about slavery and human trafficking available to its staff
Statutory guidance indicates that the Government expects companies to cover these areas in their reports but this is not compulsory.
There are currently no penalties for companies that do not comply and although the Secretary of State may enforce by way of an injunction this power has not been used.
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