Previously if an organisation was liable under the Modern Slavery Act 2015 (MSA) to produce a section 54 Transparency in Supply Chains Statement – a Modern Slavery statement – it only had to publish it on its own website.
Although some NGOs tried to maintain a register, it was very difficult and time consuming for interested parties, such as consumers, investors, employees, charities to compare and contrast statements. The aim of the registry is to make this easier. As before the government is also keen for organisations not caught by the legislation to prepare and file a modern slavery statement on a voluntary basis.
It is still not mandatory for organisations to submit their statement to the registry as the new registry is only one part of the government’s proposed changes intended to strengthen the MSA’s reporting requirements. However these will require legislative change and the government has given no indication when this will be forthcoming.
Currently, organisations are strongly encouraged to submit their most recently published statement to the registry to demonstrate that they have reported. Further details on how to submit your statement are available on the central registry.
You can also view an organisation’s statement on the central registry.
What now?
Aside from the moral imperative to combat social ills, the question of who is ultimately responsible for detecting, preventing and mitigating the risk of modern slavery occurring in a business or a supply chains is not going to go away. As such it would be prudent for any organisation to review their processes to ensure they are appropriate for the nature of the business and the consequent level of risk. Failure to spot modern slavery or to act if found could result in reputational and financial damage.
Even if you are not legally obliged to prepare a Modern Slavery Statement you may well find that your clients or customers will increasingly ask you what you are doing to assess the risk of modern slavery occurring within your business or supply chain. Failure to give a satisfactory answer could result in losing their business.
How can ICAEW help?
ICAEW’s Business and Management Faculty has set up a Modern Slavery Hub on our website which has a plethora of materials to help members, whether in business or practice, evaluate the risk, understand their responsibilities and what to do if they suspect or find evidence of modern slavery.
