Modern Slavery Act: Strengthening Transparency in Supply Chains

• Government is committed to strengthening section 54 of the Modern Slavery Act 2015 – transparency in supply chains following an Independent Review of the Modern Slavery Act.
• A consultation has been published to gather views on proposed measures intended to increase transparency and compliance.
• The Modern Slavery Act 2015 legislates to protect workers considered to be vulnerable, ensure that forced labour is prevented and consolidates previous offences relating to human trafficking and slavery. 
• Since its release, the United Kingdom has become the first country to take additional steps in Modern Slavery prevention through the introduction of Modern Slavery Statements for all companies that meet the £36m turnover criteria.
• Government are consulting on measures to increase compliance such as civil penalties, as well as changes to the types of organisations required to publish the statement and its content.
• Further details will be set out later this year.

Aspire’s Comment

It is estimated that 13,000 people are still a victim of modern slavery today, so is essential that Government establish more methods to crack down on human trafficking and modern slavery in supply chains.

Currently, s54 of the Modern Slavery Act 2015 suggests content for the statement but it is not compulsory. Government are considering making reporting on specific topics compulsory which they consider will encourage comprehensive reporting, prioritised action and consistency.

One way in which the Independent Review suggests compliance with s54 of the Modern Slavery Act 2015 could be improved is via civil penalties set as a percentage of turnover. The consultation mentioned a variable monetary penalty capped at a maximum prescribed sum. Penalties would be appealable, in line with other civil penalties. The Home Office has stated they would send warning letters prior to formal enforcement action.

The full consultation on Modern Slavery Transparency can be viewed here and closes on 17 September 2019. 

To ensure you are wholly conforming to the current requirements of the Modern Slavery Act 2015, please take a look at our Modern Slavery Act compliance services page. Please do not hesitate to contact a member of our team at Aspire if you need additional advice.