Modern slavery – how do you legislate for prevention?

Last week a debate was held at the Oasis centre in London with MP Frank Field to discuss the proposed modern slavery bill in the UK. There was a great turn out: a sizeable and passionate crowd came together. Frank delivered his points with empathy, recognizing that the Bill did not go as far as it could –particularly on supply chains.

So where does that leave business?

There was an opportunity for discussions and questions afterwards. What struck me, both at this debate and from being involved in various Home Office meetings on the subject is how little understanding or appreciation there is of existing legislation in the UK that could play an important role in helping to tackle this issue. And how the disclosure requirements have only recently been amended to require listed companies to include a reference to human rights in their annual report. Whilst guidance has been produced by the FRC on this new method of ‘strategic reporting;’ little if anything is said about how to address human rights. And the fact remains that the legislation only currently catches listed companies. What about those large privately owned corporates whose reach is global? Mars springs to mind – and look at their supply chain issues around human trafficking. Not to mention the cumulative impact of SME’s who are likely to be working as subcontractors and competing on price, to the extent that its likely they would employ underage or illegal immigrants to deliver cheaper projects.

It strikes me there is an opportunity in the process of consulting and drafting the provisions of the Bill for the Government to offer more direction in more than one area. Firstly, it might look to how the current disclosure requirements could be ‘beefed up’ to extend the requirement to include information on human rights and human trafficking to large companies, and after a period of review to SMEs. And secondly collaborate. Strategically. There does not appear to be any proper co-ordination of this Bill in relation to the Government’s recently published Good Business : Implementing the UN Guiding Principles on Business and Human Rights Nor any discussion on how the proposed EU Directive on mandatory reporting may affect any of the provisions of such a bill. And what about government sustainability reporting requirements? Could their social indicators be a means of introducing mandatory training on human trafficking?

I just hope the rumours of asking businesses to provide some kind of voluntary pledge will be doused. A mere declaration by an organization of its commitment to the eradication of trafficking is as good as nothing where there is so little readily available guidance and expertise.

The consultation for the draft bill ended on Monday 10 February. We submitted evidence on behalf of Finance against Trafficking

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