Modern Slavery Act Consultation - Fifty Eight Response

This week, the Government consultation on the Modern Slavery Act transparency in supply chains clause closed.

The Modern Slavery Act requires businesses over a certain size threshold to annually report on the action they have taken to ensure there is no modern slavery in their business or supply chain.

The consultation was seeking feedback on the threshold for disclosure and guidance for exactly what should go into a company’s annual Modern Slavery statement.

Some key aspects of Fifty Eight’s response are outlined below:

1. Companies that are defined as large by the UK Companies Act, i.e. over £36 million turnover should be required to report under the supply chains clause. This will enable the legislation to go further in helping ensure a level playing for companies.
   
   
2. There should be a central database which at least lists the companies who are required to comply with the Act, and which allows companies to flag that they have published an annual statement for their reporting period. Companies would know with clarity that they are being required to comply with the legislation, if they are listed in the database. 
   
   
3. The database would also hold a link to the annual statement on their website, to reduce overheads of the central database and ensure the most up-to-date version of the statement is available for viewers.
   
   
4. There should be a way SMEs, NGOs, and other international companies who are not required to report within the legislation, can publicly opt in as early adopters of the requirements of the Act and thus benefit from the positive consumer pressure the Act is designed to encourage.
   
   
5. An annual modern slavery statement should include the following:

• A description of the organisations business model and supply chain relationships.
  
  
• A description of the organisations policies on modern slavery, including due diligence and auditing processes.
  
  
• A description of the organisations governance and management reporting processes in relation to its Modern Slavery policies i.e. how frequently is information reported to and discussed at board level?
  
  
• Training available to those in supply chain management and the rest of the organisation.
  
  
• The organisations principal risks in relation to modern slavery, including how the organisation evaluates and manages those risks.
  
  
• Relevant key performance indicators and the organisations performance over time.
  

Consultation responses will now be collated and reviewed, with full guidance for companies due to be published ahead of the supply chains requirement coming into force in October 2015.

Please feel free to get in touch to learn more about the requirements of the Act and how it might affect your business. You can also signup to our newsletter to receive regular updates.