Response published regarding Modern Slavery: Transparency in supply chains consultation

• In July 2019 Government published a consultation regarding increasing transparency and compliance in supply chains (see our news here)
• Government has now published its response to the consultation - see the full response here
• It has been five years since the UK made it mandatory to identify and address modern slavery in supply chains, under the Modern Slavery Act 2015 (‘the Act’), and Government are committed to further strengthening measures
• Currently section 54 of the Act suggests areas that should be reported on by a business, on its modern slavery and human trafficking statements (‘statements’). However, respondents to the consultation supported the introduction of mandatory reporting areas – this is going to be taken forward
• Respondents mostly agreed that publishing a statement on a Government-run reporting service would not present any challenges – this is going to be mandated so businesses captured by section 54 of the Act will publish their statement on one reporting service
• It was suggested that there would be a single reporting deadline on which all annual statements should be published with potential civil penalties for non-compliance – a single reporting deadline of 30 September will be introduced for a shared reporting period of 1 April – 31 March
• Respondents were clear that there is a need for greater enforcement of the current requirement. However, there were mixed views on extending penalties to the public sector – this is going to be considered in line with the development of the Single Enforcement Body
• Respondents agreed that the requirement to publish a statement should be extended to large public bodies – this will be introduced and a budget threshold of £36m will be used
• For all measures which require legislative change, the Home Office intends to introduce this when parliamentary time allows

Aspire Comment

Compliance throughout supply chains has become more and more prevalent over the last 5 years since the introduction of the Modern Slavery Act 2015. There are a number of public bodies that take great interest in supply chain transparency and compliance for a number of reasons, for example;

• The GLAA – modern slavery aspects
• Home Office – immigration aspects
• HMRC – supply chain fraud
• BEIS – the introduction of a new Single Enforcement Body

Businesses are becoming more focussed on having compliant and ethical supply chains due to customer pressures, not to mention financial and reputational risk.

Is your business turnover over £36m? If it is, it is mandatory that you publish a Modern Slavery Statement on your website and you keep up to date with these changes to ensure you comply with all of your obligations under the Modern Slavery Act.