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6 May 2016

Ergon Associates

Ergon releases report setting out current state of disclosure under Modern Slavery Act

  • We have recorded and analysed more than 230 statements in our database. The vast majority are voluntary statements produced ahead of the statutory requirements.
  • With some notable exceptions most statements do not go further than general commitments and broad indications of processes.
  • For example, 35% of statements say nothing on the question of their risk assessment processes, which is surprising for statements that are intended to be based around a due diligence approach. Two-thirds do not identify priority risks, whether in terms of countries, supply chains or business areas.
  • The best-covered issues are organisational structures and policies covering Modern Slavery, and the least well-described issue relates to key performance indicators used to assess effectiveness.
  • The current basic level of detail contrasts with the expectations of civil society organisations and government. If statements do not start to cover processes, risks and actions in more detail, we may well start to see critical comment.
  • Among business relationships, supply chains are covered in most detail but contractor relationships remain a key gap, especially since agency workers and outsourced services may pose significant risks.
  • We have observed very similar wording in some statements from otherwise unrelated companies, which may point to the use of template or model statements.
  • Five sectors account for half of reports. These are: professional service providers, manufacturers, retailers, IT firms, and food suppliers.
  • The bulk of reporting companies (69%) are from the UK, North America (14%) or Europe (9%). But we are starting to see more reports (9%) from companies based elsewhere, including Japan and India