The importance for businesses operating in the UK of taking steps to address the scourge of modern slavery continues. Last month, the UK’s National Crime Agency published its latest set of National Referral Mechanism statistics. In 2016, 3,805 potential victims were submitted to the National Referral Mechanism. This is a 17% increase on the 2015 figures and demonstrates that the crimes of modern slavery are not just a problem in developing countries. This latest reporting confirms:
While much has changed since 26 March 2015 when the UK’s Modern Slavery Act 2015 (the Act) received Royal Assent, it is increasingly clear that the passing into law of the Act was just the start. For example:
There is no doubt that the commitment to combatting the crime of modern slavery has become a higher priority for the UK’s National Crime Agency. The reporting also indicates that UK police are conducting more investigations. Consequently, businesses operating in the UK are best advised to play their part too, especially as participation in future government procurement exercises will require demonstrable compliance with the Act (see below).
Many companies are starting to lead the way in responding to modern slavery. Not only are they producing and publishing their annual modern slavery and human trafficking statement but they are going above and beyond the Government’s guidance requirements for these statements. Carillion, the international construction company, is an excellent example of an organisation with a proactive approach to the business risks associated with modern slavery. It has created steering groups to assess modern slavery risks, developed and delivered new training programmes for its employees and introduced revised commercial agreements with its suppliers to seek to ensure that they comply with the Act. With an estimated annual spend of £3 billion with its international suppliers, this represents an impressive commitment.
More public reporting brings as a consequence more public scrutiny of the publicly available data relating to a business. For example, the 2017 Corporate Human Rights Benchmark has assessed and ranked 98 of the largest publicly traded companies in the world on 100 human rights indicators. To read the key findings, please click here.
However, human rights issues are not only relevant to the world’s largest publicly traded companies. A good example of this is Semantrica, a Bristol based social enterprise, which has developed tiscreport.org, stated to be the world's largest open data registry committed to ending modern slavery. This new venture is in partnership with the Welsh Government, which in its Code Of Practice on Ethical Employment in Supply Chains, will recommend that all public, private or third sector organisations receiving public funding in Wales produce written statements outlining what they are doing to combat modern slavery. It follows that businesses of all sizes operating in Wales will need to start assessing the implications of not signing up to this registry. When doing so, they will need to consider that the Tiscreport.org data is open to search by any member of the public, which brings a level of public scrutiny that many are not used to.
However, this consideration is not just limited to suppliers in Wales. Semantrica has ambitious plans. It intends to offer its data registry to other regional governments and states/provinces globally. Given Australia is currently consulting upon its own Modern Slavery Act and the EU has large-scale plans too, the business case for demonstrating and delivering upon commitments to eradicate modern slavery in business operations and supply chains is strengthening.