Modern slavery is the recruitment, movement, harbouring or receiving of people for exploitation through the use of force, coercion, abuse or deception. Unfortunately, it is still a problem both in the UK and around the world. Often the signs that it is happening are not obvious and companies may be unintentionally facilitating modern slavery within their supply chain. In recent years the government has sought to clamp down on modern slavery and make companies (particularly large companies with complex supply chains) more aware of the issues. Each year it publishes a UK Annual Report of Modern Slavery providing an overview of the measures taken to combat modern slavery over the preceding 12 months. This month, the government published its 2020 edition.
The Report highlighted that “significant progress” has been made on the issue. It is divided into five “themes”: Pursue, Prevent, Protect, Victim identification and support, International response to modern slavery and upstream prevention.
- “Pursue” relates to prosecuting and disrupting individuals and groups responsible for modern slavery. The conviction rate for modern slavery offences rose by 6.9 percent to 71.9% in the 12 months to June 2020. The number of active investigations into modern slavery increased by almost 25% over the same period.
- “Prevent” refers to preventing people from engaging in modern slavery, either as victims or offenders. Of note is the ‘Hidden in Plain Sight’ communication campaign which directly led to over 1,000 referrals to the Modern Slavery Helpline.
- “Protect” means protecting vulnerable people from exploitation and increasing safeguards and resilience against modern slavery. The government has focused on its own Modern Slavery Statement, to show the steps it is taking to eradicate the risks of modern slavery within government supply chains.
- The “Victim Identification and support” theme encompasses the need for harm reduction through improved victim identification and victim support. The Home Office is embarking on an ambitious National Referral Mechanism Transformation Programme to build on its current self-proclaimed “world beating efforts” to identify vulnerable victims and provide the support that they need to rebuild their lives.
- The “International response to modern slavery and upstream prevention” looks at the government’s work abroad to eradicate modern slavery. The government committed to providing £200 million to fight modern slavery internationally.
This is an indication that the government are continuing to take modern slavery seriously. Our large employer clients are reminded that the Modern Slavery Act 2015 requires commercial organisations that supply goods or services in the UK with an annual turnover of £36 million or more to publish an annual statement setting out the steps they are taking to prevent modern slavery in their operations and supply chain. The Act requires the board of directors to approve the Statement and for a director to sign it. Once approved, the statement must also be published in an obvious place on their website. Failure to do so can result in the Secretary of State applying for an injunction to prepare a statement. However, the more concerning outcome for employers in non-compliance, is the undoubtable effect it might have on reputation. For the same reason, we recommend employers not meeting the £36 million threshold consider producing a voluntary modern slavery statement to indicate their own commitment to eradicating modern slavery in their operations and supply chain.
Other ways employers can show their commitment to tackling modern slavery is by drafting and implementing a modern slavery and human trafficking policy as part of an employee handbook or by appointing an employee to act as a compliance officer to oversee modern slavery policy within the business.
If you require any assistance on drafting a modern slavery statement or a modern slavery and human trafficking policy, please get in touch.
