The Transparency in Supply Chains provision in the Modern Slavery Act 2015 seeks to address the role of businesses in preventing modern slavery from occurring in their supply chains and organisations.
Modern Slavery Act 2015 –Download
Transparency in Supply Chains – Download
Summary of consultation responses and next steps – Download
It is simply not acceptable for any organisation to say, in the 21stCentury, that they did not know [about slavery in the supply chain]… By increasing supply chain accountability, more workers will be protected and consumers will have greater confidence in the foods and services they buy.
-Theresa May, British Prime Minister
This requirement applies to business supplying goods or services in the UK with a turnover of £36m or more per year. However, because the turnover test is based on a business’s total global turnover, even businesses with a relatively small UK presence can be caught by the Act.
What does your organisation need to do?
If your organisation is covered by the legislation, you must produce an annual statement setting out the steps you have taken to ensure there is no slavery in your business and supply chains.
While there is no prescribed format for the statement, it should be “written in simple language that is easily understood”. The statement must also include all the steps you have taken, if any, although it is up to you what you include. Some example information is summarised below:
- your organisation’s structure, its business and its supply chains
- your organisation’s policies in relation to slavery and human trafficking
- your organisation’s due diligence processes in relation to slavery and human trafficking in its business and supply chains
- the parts of the business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps taken to assess and manage that risk
- your organisation’s effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as considered appropriate
Where should the statement be published?
The statement must be published on your organisation’s website with a link in a prominent place on the homepage. If you do not have a website, then a copy must be provided, on request, within 30 days.
What if we get it wrong?
The Government guidance is quite clear on what will happen if your organisation does not comply:
“If a business fails to produce a slavery and human trafficking statement for a particular financial year the Secretary of State may seek an injunction through the High Court… requiring the organisation to comply. If the organisation fails to comply with the injunction, they will be in contempt of a court order, which is punishable by an unlimited fine.”
Aside from legal penalties, failing to comply could cause reputation damage to your organisation. It is
important to bear in mind that the Government is not simply asking organisations to produce statements but is actively looking to increase transparency on human rights issues in the hope that greater peer and consumer pressure will drive improvements in this area.
However, for most organisations, it is the commercial, rather than the legal, implications that will be the biggest reason for ensuring compliance. Now more than ever, maintaining a good reputation is critical to an organisation’s success. With viral
news and social media, there is potential for significant reputational damage for organisations who do not take adequate steps to tackle modern slavery in their business. If gender pay reporting is anything to go by, we can expect considerable press interest in the list of non-compliant businesses.
Indeed, the rationale behind the Act is to create transparency around the ethical practices of organisations, thereby allowing customers, potential investors and the wider public to be informed about what organisations are actively doing to tackle modern slavery.
Modern Slavery Statement
Below are a number of modern slavery statements (templates) available to download for businesses to get compliant with the Section 54 of the Modern Slavery Act 2015. Complete one of the four statements that suits more of your activity and display it on the home page of the organisation website. Before you do that, make sure you adjust it accordingly to best fit your business operations and services.
More information can be found on GOV.UK by clicking here.
What Causes Exploitation?
There are various reasons that cause exploitation to take place, such as:
- Global Root Causes
- Supply & Demand
- Poverty & Economic Opportunities
Indicators are the most commonly used method of identification of modern slavery and human trafficking in practice. In addition to the initial set of indicators, the International Labour Organisation (ILO) further developed a Deplhi model (ILO, 2018).
The use of indicators is common and provides guidance for various actors and enforcers. Businesses across Warwickshire are encouraged to make themselves aware of the following victim identification indicators:
- Passport or documents held by someone else
- Injuries apparently a result of assault
- Others speaking for people you are trying to talk to
- Living in ‘degraded’ living conditions
- Injuries or impairments typical of certain jobs
- Injuries apparently from control measures such as shackles
- Lack of access to earnings
- Any evidence of control over movement either as an individual or a group
- No days off
- No holiday time
- Limited contact with family. Originating from a place intelligence suggests is a TIP source location.
- Lack of access to medical care.
- Very limited social contact
- Threat to be handed over to the authorities
- Perception of being bonded by a debt
- Threats against the person/family members
- Being placed in a dependency situation
- Imposed working conditions
- Lack of ability to negotiate working conditions
- Lack of ability to quit work environment
- Notices in foreign languages.
- Employer or manager unable to produce documents required when employing migrant labour.
- Employer or managers unable to provide records of wages paid to workers.
- Poor or non-existent health and safety equipment. No health and safety notices.
- Equipment designed or modified for operation by children.
- Evidence of labour laws being breached.
- No labour contract.
Also remember the last location of someone you suspect being a victim before coming to your attention e.g. premises likely to be used for exploitation.
Below are a number of videos highlighting modern slavery, raising awareness and helping to identify signs of exploitation.
Home Office: Stopping Modern Slavery in Business
Gangmasters and Labour Abuse Authority: Modern Slavery & Case Study
Home Office: Modern Slavery is closer than you think
The following links will provide local, national and international information on Mondern Day Slavery and Human Trafficking:
- Warwickshire Safeguarding Adults
- Warwickshire Police Protect
- Warwickshire Office of the Police and Crime Comissioner
- UNODC Global Report
- NCA MDSHT
- Eurostat Report
- EUROPOL Knowledge Report
- Europol Crime Threat Assessment
- Migration Policy Practice
- Refuge for Women and Children
- International Labour Organisation (ILO)
A range of different awareness material and posters will be available to download for different industries and business sectors. Warwickshire businesses are encouraged to raise awareness of modern slavery and human trafficking and get on board alongside other businesses to tackle this issue.
Unseen’s training is aimed at professionals whose work may bring them into contact with potential victims of slavery. In the past we have trained Local Authorities, Police, Fire and Rescue, Housing Associations, Environmental Health Officers, Social Workers, NGOs, businesses and many other sectors.
Training gives you the benefit of our decade’s experience of working on the issue at every level – working with victims and survivors, collaborating with law enforcers and government bodies, contributing to policy and research, running the Modern Slavery Helpline – compressed into practical, CPD-accredited courses.
Join the course or explore bespoke training. You can either book on to one of the Frontline: Modern Slavery Training courses, or bespoke training sessions, tailored to the needs of your organisation could be developed. More information on the Unseen website by clicking here.
These videos will provide an overview of what Modern Slavery is, detailing the typologies, how to spot the signs of someone being a victim of Human Trafficking, and how you can equip yourself to react effectively to incidences of Modern Slavery.
1. What is Modern Slavery and Trafficking?
2. Victim Indicators
3. The NRM, duties and requirements
4. Responding to a potential victim of trafficking