On 11 March 2021, the UK Home Office launched a central registry of modern slavery statements, which follows the government’s commitment to introduce various changes to the section 54 reporting regime under the UK Modern Slavery Act 2015 (the “Act”). The intention is that a central registry will increase transparency for consumers and investors, enabling them to see the steps organisations are taking to prevent slavery in their supply chains.
Following a recommendation from the 2019 independent review of the Act, this new registry will replace the current voluntary initiative run by the non-profit Business and Human Rights Resource Centre, which has played a central role in monitoring compliance for more than four years.
Under section 54 of the Act, commercial organisations are required to produce a statement each year which sets out the steps they have taken to ensure their businesses and supply chains are slavery free. A “commercial organisation” is one that supplies goods or services in the UK and has an annual turnover of £36 million or more, including turnover of subsidiaries. The government may issue civil proceedings to require a commercial organisation to produce a statement if they do not do so voluntarily. However, the government cannot impose monetary penalties for non-compliance.
Currently, submission of those statements to the registry is voluntary, but all organisations are encouraged to submit their statements online. It is expected that, in time, it will become mandatory. However, this will require legislative change and the timeline is currently unclear with the only guidance being “when parliamentary time allows”. Interestingly, the requirement is limited to producing a statement. Therefore, an organisation can submit a statement admitting that it has not taken any steps to ensure there is no slavery in its business or supply chain, thereby complying with its reporting obligations.