Potential strengthening of modern slavery reporting requirements

The Queen’s Speech in May 2022 announced the Government’s intention to introduce a Modern Slavery Bill. 

An update to the existing Modern Slavery Act 2015 requirements has long been promised, with the current reporting requirements of section 54 often described as toothless, since those organisations caught by the requirement can satisfy it simply by publishing a statement that they have taken no steps to address human trafficking in their supply chains, and furthermore there is no penalty available at the moment for those organisations that fail to comply with the limited reporting requirements.

In May 2019 the Government published an independent review of the Modern Slavery Act 2015, with its own response following in July 2019, accepting most of the recommendations in the review.  The Government then launched a consultation on proposed changes to section 54, with its response to the consultation following in September 2020.

A new strategy was due to be published in Spring 2022, though has yet to materialise. 

It is anticipated that a new Modern Slavery Bill* may:

  • extend the range of organisations caught by the requirement to report;
  • require that statements are published to a specified Government registry (currently voluntary);
  • introduce a single reporting deadline;
  • provide a mandated format for board approval of a modern slaver statement;
  • provide civil penalties for non-compliance;
  • mandate the details to be provided in a modern slavery statement.

The latter details are expected to include an organisation’s:

  • structure and nature;
  • policies on modern slavery;
  • due diligence processes;
  • assessment of particular risks and the steps taken to mitigate those;
  • assessment of the effectiveness of such steps;
  • training and resources available to staff.

*It is possible that new requirements might be introduced instead via a new Procurement Bill.

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