The UK is Ramping Up Reporting Requirements for Modern Day Slavery Act

by Source Intelligence

on October 23, 2020

According to the National Crime Agency, modern slavery and human trafficking in the UK are "far more prevalent than previously thought, and are likely widespread in the United Kingdom.”


Ever since the Modern Slavery Act of 2015, our neighbors across the Pond have been determined to keep fighting forced labor and human trafficking in supply chains, both within and far beyond their borders. Modern-day slavery takes many forms and is estimated to affect tens of millions of people around the world.


The British government is inclined to extend reporting deadlines so as to not overburden organizations already taxed by the consequences of the pandemic, but it is also working toward amending its Modern Day Slavery Act and ramping up reporting requirements.



UK Modern Slavery Act: Background and Scope



Introduced in 2013 under the sponsorship of then Home Secretary Theresa May, the bill received Royal Assent in March 2015 and became an Act of Parliament, i.e. law.


Its intent to combat modern slavery is supported by several provisions, keys of which are the consolidation of offenses relating to forced labor and human trafficking and the Transparency in Supply Chains Provisions.


The Act requires that businesses publish an annual statement if:


  1. They are commercial organizations
  2. That conduct whole or part of their business in the UK
  3. With an annual turnover of at least £36 million


Other notable supporting key areas of the bill include:


  • Creation of two new civil orders to prevent slavery
  • Establishment of an Anti-Slavery Commissioner
  • Provisions for the protection of victims



2020 and Forward: Goals and What to Expect



In the 2019-2020 report, Independent Anti-Slavery Commissioner Dame Sara Thornton outlines the four priorities of her strategic plan to prevent modern-day slavery and trafficking from flourishing:


  1. Improving victim care and support
  2. Supporting law enforcement and prosecutions
  3. Focusing on prevention
  4. Leveraging research and innovation


These four axes highlight the need and intention to work closely within the scope of the Act, as further suggested by the Government’s response to the public consultation it launched in 2019.


In September 2020, the UK Government announced its commitment to


“an ambitious package of measures to strengthen and future-proof the Modern Slavery Act’s transparency legislation.”


While its priorities are currently heavily focused on managing the COVID-19 crisis, the Government plans to add amendments to the Act to its legislative calendar.



Current Reporting Guidelines of the Modern Day Slavery Act



As of today, businesses are not subjected to a formal structure to file their annual report. Based on key compliance areas, however, the statement should include at least the following:


  • Business structure
  • Sustainability commitment
  • Approach to compliance
  • Corporate policies
  • Due diligence efforts



Expected Changes and Additions to the Act



As a result of the consultation, the UK Government is reviewing several changes and introducing various additions:



Report Submission


Companies will submit the statements to a new Government Registry.


Companies will file according to a single deadline. Statements will cover the April 1 through March 31 period and will be due on September 30.



Report Content


Six topics will become mandatory, as suggested by 78% of respondents:


  1. Description of organizational structure, business model, and relationships in the supply chain
  2. Policies currently published and applicable
  3. Due diligence and auditing processes and methodology
  4. Human trafficking risk assessment and mitigation plan
  5. Compliance effectiveness supported by KPIs
  6. Internal training programs


Further amendments will require that the statements bear the date of approval by the board and director sign-off. In the case of group statements, the names of all covered entities shall be listed.




Fighting Modern Day Slavery with Source Intelligence




Even if it were not for compliance purposes, mitigating the risk of modern-day slavery all throughout the supply chain would benefit organizations on many levels, most important of which is probably brand reputation and customer loyalty, which in turn appeals to investors as much as profit statements, if not more. The fact that 73% of responses to the public consultation were from consumers proves once again the importance of ethical business practices, if only from a business standpoint.


Source Intelligence’s anti-human trafficking program is multipurpose by design: integrating legal compliance requirements with social corporate responsibility.


Our AI-powered solution seamlessly works with all three major anti-slavery regulations: FAR 52.222-50, California SB-657, and the UK Modern Day Slavery Act.


Based on the OECD due diligence guidelines on responsible sourcing, we’ve created a platform that addresses both the logistic aspects of collecting data and the need for a uniform and simplified reporting template that your suppliers can use.


The program is further enhanced by AI-powered document validation, geographical risk-mapping, and multi-tier supplier engagement.


Should you wish to take your strategic efforts against modern forced labor further, we also offer premium customizable features like whistle-blower services, high-risk supplier assessments, and virtual audits.


Despite the apparent differences in reporting media and requirements, reaching global compliance need not be overwhelming. A one-stop solution saves you the hassle of multiplying your efforts and dispersing your resources, all the while providing you with the visibility and insights that help prevent fines, penalties, and public relations nightmares.


To learn more, download our guide to UK Modern Day Slavery Act compliance.


Download Our Guide

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