0370 270 6000

A new Modern Slavery Bill

26 May 2022

The Queen’s Speech

The Queen’s Speech on 10 May 2022 outlined the Government’s legislative plans for this parliamentary session. These include the introduction of a Modern Slavery Bill with the purpose of:

“strengthening the protection and support for victims of human trafficking and modern slavery and to increase accountability of companies and other organisations to drive out modern slavery from their supply chains”.

Modern Slavery Bill

Details of the Modern Slavery Bill have not yet been published, but the announcement in the Queen’s Speech is consistent with the Government’s response to a consultation exercise on changes to the Modern Slavery Act 2015’s transparency in supply chains provisions. In a foreword to the response the Home Secretary said:

“We will extend the reporting to public bodies to leverage public procurement and address risks in public sector supply chains. We will also mandate the specific topics statements must cover, set a single deadline for reporting and require organisations to publish directly to the new government reporting service, to empower investors, consumers and civil society to scrutinise the action taken across the private and public sector.”

Enforcement

The consultation exercise highlighted the need for greater enforcement of the current modern slavery reporting requirements. The Government has stated that it will consider enforcement options in line with the development of the single enforcement body for employment rights now in development.

Financial Reporting Council

The announcement of the Modern Slavery Bill was made a month after the Financial Reporting Council published its report on how a sample of 100 companies listed on the London Stock Exchange’s Main Market report on modern slavery, both in mandated modern slavery statements and in annual reports.

The Report states that 12% of the companies sampled failed to provide a modern slavery statement, while those that were provided were found to be unclear and fragmented. Less than half of companies’ statements identified and discussed modern slavery issues in the context of their organisational structure, and few were proactive in their approach to modern slavery.

According to the Report modern slavery generates an estimated US$150 billion annually and encompasses 40 million people in slavery globally. The UK is far from immune to modern slavery. In the year to September 2021, 9,158 modern slavery offences were recorded by the police. Many commentators believe that this statistic is a tiny fraction of the reality of the situation in this country.

Conclusion

Public sector and private sector organisations, particularly those who meet the £36 million threshold, are encouraged to review their approach to combating modern slavery in their organisation and its supply chains before the Modern Slavery Bill becomes law.

Understanding your organisation and its supply chains from a modern slavery perspective is almost invariably a complex and time-consuming exercise, as is ensuring that action is taken to protect the organisation from the supply chains of its suppliers. Time should not be lost to explore these matters - or to re-explore them.

How the Government will deal with enforcement remains to be seen but preparing for these new laws should be a priority for many organisations to protect victims of modern slavery, the reputation of the organisation and ensure legal compliance.

A mandatory requirement to publish modern slavery statements on the government registry should drive up both compliance and the quality of statements. A central, public repository makes it easy to check whether an organisation has published a statement, to review progress year on year and to compare its statements to those produced by different organisations in the same sector, including competitors.

Training and events

13Dec

Claims Club London office

We are pleased to invite you to join us for our popular Claims Club, which will take place in-person in our London office. With a focus on risk in the public sector, as well as discussion on the topics outlined below we are hoping there will be time for Mr Jonathan Cook to don his sparkly jacket for a short festive quiz! Following the session there will be an opportunity for an informal catch up for those who can stay on.

View event

12Jan

EdCon2023: Planning for the future Online

We're delighted to offer you a complimentary invitation to our EdCon2023 online platform - a virtual event space where you will have the opportunity to hear from our education lawyers and HR experts.

View event

Focus on...

Guides

Good governance essential to avoid falling foul of the ESFA

There’s been little evidence of interventions or financial management reviews this year and it appears the Education and Skills Funding Agency (ESFA) has re-focussed on financial delivery. It’s also telling that there were no discernible changes to the reporting of financial irregularities in the Academies Trust Handbook 2022.

View

Legal updates

Hair discrimination – stop pupils being unfairly singled-out for their appearance

The Equality and Human Rights Commission (EHCR) has issued new, non-statutory guidance regarding the wearing of natural or protective hairstyles, specifically in reference to their representation in uniform, behaviour or standalone appearance policies. This guidance has been designed to complement and enhance the guidance already given on school uniform and Equality Act 2010.

View

Legal updates

School complaint management - exploring a new way forward

There’s greater opportunity than ever for parents, carers and guardians to voice any concerns they have relating to their child’s education and for their concerns to be heard and to be taken seriously.

View

The UK's green agenda - the outcomes of COP27 and actions since COP26

Just over a year ago world leaders, policymakers, scientists and environmental activists gathered in Glasgow for COP26. Now many of those same people have also travelled to Egypt to attend this year's summit for what has been billed as “A moment of truth for the international community”.

View

The content on this page is provided for the purposes of general interest and information. It contains only brief summaries of aspects of the subject matter and does not provide comprehensive statements of the law. It does not constitute legal advice and does not provide a substitute for it.

Mailing list sign up

Select which mailings you would like to receive from us.

Sign up