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Eversheds comment: A cautious start to business reporting under the Modern Slavery Act

  • United Kingdom

    27-10-2016

    One year after the Modern Slavery Act imposed a duty on qualifying businesses (starting with businesses with year-ends from 31 March 2016 onwards) to report on steps taken to ensure their operations and supply chains are trafficking and slavery free, hundreds of slavery and trafficking statements have now been published. Thomas Player, partner and employment law expert at Eversheds, comments:

    “Some of the slavery and trafficking statements published to date show significant efforts by organisations to examine their role in preventing slavery and trafficking. Even where statements are more cursory in nature, the mere fact of publication reflects a recognition that corporate accountability matters.

    “However, the majority of the statements signal a cautious approach, with many businesses not yet identifying specific slavery and human trafficking risks, how those risks are managed and the effectiveness of steps taken, as suggested under the Act. Reflecting early days with the Act, this is probably due to organisations being insufficiently advanced in their anti-slavery efforts to have such information to disclose, or because they feel uneasy about sharing such information, particularly where competitors stay silent.

    “With the UK Government already being lobbied to strengthen the Act’s reporting provisions and the fight against modern slavery being championed personally by Theresa May, those businesses in high risk sectors that do not show reasonable and proportionate efforts to tackle modern slavery, particularly in their supply chains, should expect critical scrutiny. This initial, informal period of grace to allow businesses to organise their response will come to an end.”

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