UK Government: Transparency in Supply Chains etc. A practical guide

The Trans­paren­cy in Sup­ply Chains pro­vi­sion in the Mod­ern Slav­ery Act seeks to address the role of busi­ness­es in pre­vent­ing mod­ern slav­ery from occur­ring in their sup­ply chains and organisations.

1.1 Mod­ern slav­ery is a crime result­ing in an abhor­rent abuse of human rights. It is con­sti­tut­ed in the Mod­ern Slav­ery Act 2015 by the offences of ‘slav­ery, servi­tude and forced or com­pul­so­ry labour’ and ‘human traf­fick­ing’. A full def­i­n­i­tion of mod­ern slav­ery is includ­ed at Annex A.

1.2 Many organ­i­sa­tions are already tak­ing action to pro­mote eth­i­cal busi­ness prac­tices and poli­cies that pro­tect work­ers from being abused and exploit­ed in their own organ­i­sa­tion and glob­al sup­ply chains.

1.3 How­ev­er, there are still far too many peo­ple in the world being treat­ed as com­modi­ties. There are also far too many organ­i­sa­tions ignor­ing such abus­es or who are know­ing­ly respon­si­ble for poli­cies and prac­tices that result in work­ers being sub­ject­ed to mod­ern slav­ery in their operations.

1.4 The Gov­ern­ment has intro­duced a pro­vi­sion in the Mod­ern Slav­ery Act 2015 which requires cer­tain busi­ness­es to pro­duce a state­ment set­ting out the steps they have tak­en to ensure there is no mod­ern slav­ery in their own busi­ness and their sup­ply chains. If an organ­i­sa­tion has tak­en no steps to do this, their state­ment should say so. The mea­sure is designed to cre­ate a lev­el play­ing field between those busi­ness­es, whose turnover is over a cer­tain thresh­old, which act respon­si­bly and those that need to change their poli­cies and prac­tices. How­ev­er, the Gov­ern­ment wants to encour­age busi­ness­es to do more, not just because they are legal­ly oblig­ed to, but also because they recog­nise it is the right thing to do.

1.5 One key pur­pose of this mea­sure is to pre­vent mod­ern slav­ery in

organ­i­sa­tions and their sup­ply chains. A means to achieve this is to increase trans­paren­cy by ensur­ing the pub­lic, con­sumers, employ­ees and investors know what steps an organ­i­sa­tion is tak­ing to tack­le mod­ern slav­ery. Those organ­i­sa­tions already tak­ing action can quick­ly and sim­ply artic­u­late the work already under­way and planned. Organ­i­sa­tions will need to build on what they are doing year on year. Their first state­ments may show how they are start­ing to act on the issue and their planned actions to inves­ti­gate or col­lab­o­rate with oth­ers to effect change.

1.6 This doc­u­ment sets out the basic require­ments of the leg­is­la­tion, as well as advice on what can be includ­ed in a state­ment to give assur­ance to those scru­ti­n­is­ing the statements.

1.7 A focus on tack­ling mod­ern slav­ery not only pro­tects vul­ner­a­ble work­ers and helps pre­vent and rem­e­dy severe human rights vio­la­tions, it can bring a num­ber of busi­ness ben­e­fits too. These include:
• pro­tect­ing and enhanc­ing an organisation’s rep­u­ta­tion and brand;
• pro­tect­ing and grow­ing the organisation’s cus­tomer base as more con­sumers seek out busi­ness­es with high­er eth­i­cal standards;
• improved investor confidence;
• greater staff reten­tion and loy­al­ty based on val­ues and respect; and
• devel­op­ing more respon­sive, sta­ble and inno­v­a­tive sup­ply chains.

1.8 It is impor­tant for large organ­i­sa­tions to be trans­par­ent and account­able, not just to investors but to oth­er groups includ­ing employ­ees, con­sumers and the pub­lic whose lives are affect­ed by their busi­ness activ­i­ty. Due dili­gence process­es and report­ing are essen­tial man­age­ment tools that improve risk iden­ti­fi­ca­tion and long-term social, envi­ron­men­tal as well as finan­cial performance.

1.9 Report­ing require­ments can dri­ve bet­ter strate­gic under­stand­ing of the risks and impacts of an organisation’s core activ­i­ties in rela­tion to the envi­ron­ment and human rights. The dis­clo­sure of these man­age­ment tools allows investors to move cap­i­tal towards more sus­tain­able, respon­si­ble organ­i­sa­tions and strength­en the long-term eth­i­cal sus­tain­abil­i­ty of the finan­cial system.included in a state­ment to give assur­ance to those

scru­ti­n­is­ing the statements.

This doc­u­ment pro­vides guid­ance on how the Gov­ern­ment expects organ­i­sa­tions to devel­op a cred­i­ble and accu­rate slav­ery and human traf­fick­ing state­ment each year and sets out what must be includ­ed in a statement.