1. Is modern slavery an issue in the UK?
Modern slavery is most definitely an issue in the UK, even if the extent is not as great in other parts of the world. Back in 2013, the UK Home Office estimated there were 10 to 13 thousand people in the UK working in slavery-like conditions, a recent study by the Centre for Social Justice suggests that the real figure could be over 100 thousand. This is what prompted the UK Government to enact the Modern Slavery Act in 2015 to specifically target this crime.
2. What obligations does the Modern Slavery Act impose?
The UK Government has been careful not to create more red tape than necessary for companies under the Modern Slavery Act 2015. The key requirement is for companies with a turnover of £36 million or higher to produce an annual Slavery and Human Trafficking Statement. Companies will also need to provide a prominent link to the Statement on their website.
3. Do I need to worry about modern slavery in my supply chain?
Your annual Slavery and Human Trafficking Statements must include the efforts that your company has made to eradicate slavery from its supply chain, as well as its own business. Obviously policing the supply chain represents a whole new level of challenge, as well as potentially higher costs for companies. The Act and associated guidance don't mandate any specific steps, and they don't require companies to guarantee that their supply chain is entirely slavery-free.
A company could simply say that it has done nothing about slavery in its supply chain, but that's likely to lead to negative publicity. So most large companies can be expected to take some steps to engage their suppliers.
4. What is meant by the 'Race to the Top'?
Whilst everyone agrees that modern slavery is inhumane and must be stamped out, there is disagreement about the role that companies can play. The UK Government has opted for an innovative approach to regulation with the Modern Slavery Act. The only mandatory requirement for UK companies (only the large ones) is to publish an annual Slavery and Human Trafficking Statement linked prominently from their website.
The Government expects pressure from the media, NGOs, employees, customers, shareholders and indeed competitors to drive companies to demonstrate progress year on year in a race to the top (and drag their suppliers - the smaller companies - up there with them).
5. What should my Modern Slavery Statement look like?
There are no specific requirements in relation to the layout, content or level of detail of the Slavery and Human Trafficking Statements.
The UK government has suggested that each company should include:
- Its structure, business and supply chains
- Policies in relation to slavery and human trafficking
- Due diligence carried out in relation to slavery and human trafficking in its own business and supply chains
- 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
- Its effectiveness in eradicating slavery and human trafficking from its business and supply chains, measured against appropriate performance indicators
- Training on slavery and human trafficking provided to its staff
Want to learn more about Modern Slavery?
You can find lots of useful links to key modern slavery facts, figures, tips and training in our comprehensive guide to Modern Slavery Resources.
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