Modern Slavery Ranks as Top Priority for the UK Government

Modern Slavery Ranks as Top Priority for the UK Government

Modern slavery is a crime and a violation of fundamental human rights that can take various forms. After a year that saw trade compliance fluctuations and increasing country of origin requirements, human trafficking and slavery concerns throughout the global supply chain have also grown. In response, the UK government spent approximately $51 million (39 million British pounds) in 2017–18, and $80 million (61 million British pounds) in 2018–19.

The dollar figures cover direct spending by the government on efforts to eradicate modern slavery, such as funding the independent Anti-Slavery Commissioner, and includes the costs of programs such as the Child Trafficking Protection Fund and the Adult Victim Care Contract. These actions reaffirm its commitment to fighting international human trafficking and slavery in supply chains.

However, a 2017 report found that 40 percent of the UK government’s own top suppliers failed to meet modern slavery due diligence standards. This report came on the heels of many others showing poor reporting among in-scope companies. In response, the UK Home Office sent letters to 17,000 companies in October 2018 requesting they register on the Modern Slavery Contact Database and publish compliant Modern Slavery Statements by March 31, 2019, or be publicly named as offenders.

An independent review of the Supply Chain Transparency Provision of the Modern Slavery Act, commissioned by the UK government and released in January 2019, is expected to strengthen current legislation and shape the government’s future response to modern slavery. It recommends:

  • Tougher sanctions, fines, director disqualification and court summons to tackle non-compliance.
  • Mandatory disclosure topics and referencing the modern slavery statement in their annual reports.
  • Increased transparency by creating a central, government-run repository (similar to the Australia Modern Slavery Act 2018).

The UK government isn’t the only jurisdiction prioritizing modern slavery. In an article published last year, the U.S. Department of Defense reconfirmed its aggressive stand against all activities that may contribute to trafficking, including throughout its contractors’ supply chains. In December 2018, the U.S. government amended the Federal Acquisition Regulation (FAR)to broaden the definition of recruitment fees, further implying its continued focus on combating human trafficking and slavery in supply chains.

Does My Company Need a Modern Slavery Statement?

Section 54 of the Modern Slavery Act 2015 requires large employers with an annual revenue of at least $45 million (36 million British pounds) to produce a modern slavery statement for each financial year, including information on the company’s:

  • Structure, policies, business and supply chains.
  • Due diligence processes relating to human trafficking and slavery in its supply chains.
  • Supply chains at risk and steps taken to mitigate that risk.
  • Available training and education for employees regarding slavery and human trafficking.

To meet minimum legal requirements, Modern Slavery Statements must be:

  • Updated every year.
  • Published on the company’s UK website.
  • Approved by the Board of Directors.
  • Signed by a director (or equivalent).

Following the March 31, 2019 audit of modern slavery statements, the UK Home Office intends to publish a list of non-compliant companies. This marks the first time the government will publicly name organizations for non-compliance.

Companies that are published on this list will suffer reputational damage, which could result in adverse media, lowered stock value, investor fallout, and loss or lack of renewal of contracts. Companies should ensure their statements are compliant and their supply chain due diligence processes, risk mitigation programs and supplier engagements stand up to external scrutiny.

As part of the Assent Compliance Platform, the Corporate Social Responsibility Suite helps companies streamline and automate their corporate social responsibility (CSR) programs. The Human Trafficking and Slavery Module supports companies in efficiently collecting and managing supply chain data to identify and mitigate human rights-related risk.

To learn more about how Assent can help you manage your CSR program, email us at info@assentcompliance.com.

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