The Independent Anti-Slavery Commissioner, Dame Sara Thornton, has published a report following an investigation into how businesses are using the Modern Slavery Statement Registry. She found that although the government ‘should be congratulated for fulfilling its commitment to build a centralised on-line registry’, there are still ‘implementation problems within the registry that need to be addressed’.
Under s.54 of the Modern Slavery Act 2015, businesses in the UK with a turnover of at least £36 million per year are required to do the following:
- publish annual Statements on their actions to identify, prevent and mitigate modern slavery in their supply chains, setting out the steps the organisation has taken to ensure that slavery and human trafficking is not taking place in their supply chains or any parts of their own business (s.54(4));
- publish their Statements on their website if they have one, and if they do not, make it available upon request (s.54(7) and (8)); and
- ensure that statements are approved at the highest level of governance and signed by a senior member of the organisation (s.54(6)).
The Act also encourages non-government entities such as NGOs, investors, and consumers, to read company Statements and hold businesses to account.
In March 2021, the government launched the voluntary Modern Slavery Statement Registry to aid corporate transparency. The IASC looked at 50 statements published by companies on the registry and found that many did not properly link their modern slavery statement and provided inaccurate information. Only 45% of the companies that published their statement on the registry provided links that went straight to their statement. The remaining 55% of companies provided links that went to the company home page, links that did not work and some claimed that they did not have a website, when a significant proportion of those claiming did.
The report found that although the registry is a powerful tool, most companies are not using it properly and without proper enforcement, s.54 of the Act remains largely ineffective.
The law requires companies that satisfy the criteria to publish a modern slavery compliance statement. Southwell and Partners specialises on advice on modern slavery compliance law, should you require any advice please get in touch.