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27 Nov 2015

Elise Groulx Diggs, Doughty Street Intl., Catherine Meredith, Doughty Street Chambers, Vera Padberg, Doughty Street Intl.

The Modern Slavery Act 2015: corporate reporting requirements to tackle slavery in supply chains

First, the starting point should be human rights due diligence to tackle slavery and trafficking in supply chains as found in the UN  Guiding Principles on Business and Human Rights (the ‘Ruggie’ principles).

Secondly, and practically speaking, the reporting obligation will only apply to financial years starting on or after the 1st of April 2016. Companies, therefore, do not have long to gear up for this new obligation, and numerous changes may be required to ensure compliance. Some of these changes may include:

  • Engaging with the key areas identified by the Government in the response to the consultation (above) and considering how to address these with a focus on human rights due diligence;
  • Developing anti-slavery and human trafficking policies; and/or including these in  corporate social responsibility (CSR) policies;
  • Developing processes to investigate business and supply chain (contractors, sub-contractors, suppliers, contracts, etc.) to determine the level of risk or exposure to risk;
  • Identifying and prioritising high risk areas in the supply chain and planning and setting out what steps are being taken to address the risks;
  • Appointing senior individual(s) within companies with responsibility for investigation, compliance and the production of the statement;
  • Identifying training needs within companies to ensure that all responsible staff involved in supply chain management and procurement are aware of the new obligations;
  • Putting effective grievance and whistle blowing mechanisms in place to cover any concerns about slavery or human trafficking within any business or supply chain.

Thirdly, it may also assist to prepare a draft statement as soon as possible to ensure consideration and avoid having to rush as the obligation deadline approaches.