Modern slavery

You may have consigned the Modern Slavery Act 2015 to the list of legislation that you feel you don’t need to do anything about, perhaps because you don’t trade globally as an organisation, or because you don’t have a turnover of £36 million, and so you’re not required to publish annual transparency statements (setting out what the organisation is doing to stop forced labour practises occurring in the organisation and in its supply chain).

Amongst those organisations that are bound to comply with this, it is estimated that only 60% have actually done so, and there is concern where organisations have information, they haven’t gone far enough to set out their policies, the due diligence processes that will apply, the risks they have identified and the steps they’re taking to mitigate them, as well as training.

The only pressure being applied to amend the legislation is to force public bodies to come into scope and to use their extensive procurement power as leverage to make those sorts of reporting requirements mandatory.

Because it is only a very small group of my clients who have been interested in this topic area it is probably one that I have also placed less emphasis on. However, the slavery index puts the number of people trapped in modern slavery in the UK today at 136,000, and it’s not until you hear stories of people working in car washes, night cleaning and food production, you then start to feel that this isn’t an area that we can turn a blind eye to, even if it takes a while for the law to catch-up and more than nudge you into action.

Do you know who is cleaning your office at night? Do you know if they’re in control of their own passport? If we have outsourced something to a third party, do we know anything about their labour force?

In December, the Guardian reported that the NHS had been using medical gloves made in a Malaysian factory where migrants were allegedly subject to forced labour, forced overtime, debt bondage, withheld wages and passport confiscation. Can you safely say your suppliers don’t fall into that category?

Do we need to do more, not because the law tells us to, but because it’s the right thing to do?