In September 2020, the Government published a response to the ‘Transparency in supply chains consultation’. The consultation was twofold, covering changes to reporting requirements for commercial organisation and extending reporting requirements to the public sector.   

The consultation showed a support for mandating specific topics for organisations to report against in their modern slavery statements. Organisations will not be mandated to report against the new areas until the necessarily legislative changes have been made. However, the Home Office has committed to publish updated ‘Transparency in supply chains guidance’ which will be further updated following legislative change. The Government continues to develop a new Government-run reporting service which organisations will be encouraged to use before any legislative mandate.  

As for the public sector, the Government plans legislative change to incorporate public bodies with a budget threshold of over £36 million into mandatory reporting laws. The Home Office has committed to publishing guidance ahead of any legislative change to help public bodies establish whether they will fall under the mandatory reporting requirements. The consultation response indicates that public bodies will be allowed to publish group statements.  

Future legislative changed will also:  

  • Require organisations to report to a single reporting deadline  
  • Clarify the requirements on Board approval for commercial organisations  
  • Require statements published by public bodies to be signed off by the accounting officer, chief executive or equivalent role; and approved by the senior management body  

The Government highlighted it will consider enforcement and the introduction of civil penalties for non-compliance along with potential creation of an enforcement body. This would be a significant shift in policy, as to date no enforcement nor penalties exist for non-reporting.  

The full Government response to the ‘Transparency in supply chain consultation’ can be found here.  

Southwell and Partners provide expert legal advice and training to companies on modern slavery compliance. If you would like an further information please get in touch.