Modern slavery: where does it fit in with your ESG strategy?

In The Abuse of Power: Confronting Injustice in Public Life, former Prime Minister Theresa May talks about the critical role that businesses play in the work to stop slavery. With the advent of the Modern Slavery Act 2015 (the Act), some companies have incorporated this under the Environmental, Social and Governance (ESG) agenda.

What is modern slavery?

The Office for National Statistics (ONS) report on Modern slavery in the UK highlighted the link with organised crime. The exploitation can take many forms, including:

• labour exploitation 
• sexual exploitation 
• domestic servitude 
• criminal exploitation 
• organ harvesting

By its nature, it is difficult to measure the prevalence of modern slavery accurately. The ONS cited qualified estimates of the number of potential victims in the UK:

• 10,000 – 13,000 (Home Office, 2014) 
• 136,000 (Walk Free Foundation, 2018)

What are your obligations?

Under the Act, a commercial organisation must publish an annual modern slavery statement if all the following apply:

• it is a body corporate or a partnership, wherever incorporated or formed
• it carried on a business, or part of a business, in the UK
• it supplies goods or services
• it has an annual turnover of £36 million or more

The Home Office statutory guidance provides that a commercial organisation:

• should publish its slavery and human trafficking statement as soon as possible after its financial year-end, and at most, within six months of the financial year-end
• may decide to publish the statement at the same time as it published other annual accounts

What can you do anyhow?

Even if it doesn’t fall within obligation, you can voluntarily publish a slavery and human trafficking statement. In our experience, smaller organisations commonly do this when bidding for contracts with businesses legally obliged to publish a modern slavery statement.

The Home Office suggests that all businesses should be encouraged to be open and transparent about their recruitment practices, policies, and procedures about modern slavery and take steps consistent and proportionate with their sector, size, and operational reach.

Make a statement!

A slavery and human trafficking statement should, according to the Home Office, be:

• written in simple language to ensure that it is easily accessible to everyone
• succinct, but cover all the relevant points and link to your relevant publications, documents or policies
• in English, but may be provided in other languages relevant to your supply chain

It must include either:

• the steps you have taken during the financial year to ensure that slavery and human trafficking is not taking place in any of your supply chains, and in any part of your own business, or
• that you have taken no such steps

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