Open-access registry for the Modern Slavery Act critical & urgent
The Modern Slavery Act 2015 requires commercial organisations operating in the UK and with an annual turnover above £36m to produce a statement setting out the steps they are taking to address and prevent the risk of modern slavery in their operations and supply chains.
A number of key stakeholders that were influential in securing the inclusion of a Transparency in Supply Chains (TISC) clause in the Modern Slavery Act advocated for the Government to create a central database or ‘registry’ that would host all modern slavery statements. We remain convinced that a registry is essential to enable the public to review the statements, hold companies to account for compliance with the legislation, and to evaluate companies’ commitment and actions in tackling the risks and incidence of modern slavery.
The Government has been consistent in stating that it will not establish this central registry, but agrees that it would be valuable.
In light of this, a number of key stakeholders – the ETI, Business & Human Rights Resource Centre, Anti-Slavery International, FLEX, KnowTheChain, Humanity United, Freedom Fund and CORE Coalition - have agreed that a transparent, free and open access registry is critical and urgent, and are discussing how to make this a reality. We want a registry to drive increased transparency, lesson learning and continuous improvements in reporting and responses by companies to tackle modern slavery. We have also communicated with the Independent Anti-Slavery Commissioner who supports this aim.
We have agreed that a central registry should meet a core set of criteria. It should be: independent, accountable to the public interest, robust, credible, free, open, accessible and sustainable in the long term. We feel it is vital that there exists a platform that is searchable by type of company, sector and size. This will enable the public, civil society, parliamentarians, the government, investors and others to review and analyse the statements in relation to compliance with the legislation and quality of reporting.
We will consult to ensure that any registry has the support and endorsement of critical actors with expertise on modern slavery, and a primary interest in the protection of workers and human rights. One that can be used by civil society to press for meaningful action to tackle modern slavery. As such, governance and oversight arrangements will be critical, involving key civil society actors such as trades unions and NGOs.
We are committed to consultation with companies that have been actively engaged in advocating for TISC in the Modern Slavery Act, and to working closely with industry bodies such as the British Retail Consortium. We want to ensure that there is a registry that is fit for purpose and that it meets the primary concern of companies committed to responsible and ethical practices – that is, to create a level playing field for all businesses.
At the same time, we will continue to press the UK Government to make available a list of all companies required to report and to ensure that government has the relevant mechanisms in place to monitor compliance with the TISC provisions of the Modern Slavery Act.
We are keen to build on what exists already and to benefit from open access statements that are in the public domain – posted on company websites or other sites.
We will provide an update on progress in September.
Current list of statements, compiled by Business & Human Rights Resource Centre
Analysis of early statements under the Act, and guidance by CORE Coalition