Government response on strengthening modern slavery reporting requirements

The government has published its response to its transparency in supply chains consultation. The response sets out significant new proposals intended to strengthen the Modern Slavery Act 2015 (MSA), and in particular the statement on transparency in supply chains required under section 54 of the Act.

The proposed measures, which the government consulted on in July 2019, include:

• Contents – It is proposing to mandate the areas that modern slavery statements must cover. These mandatory areas will include the current six voluntary areas (that is, the organisation’s structure, its business and its supply chains; its policies; its due diligence processes; the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk; its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains; and the training about slavery and human trafficking available to its staff). Some new areas may also be included.
• Timing – There will be a set reporting period for all entities of 1 April to 31 March, and a single reporting deadline of 30 September. This will mean that organisations that do not have a 31 March year-end will need to adjust their reporting timelines.
• Publication – Organisations will be required to publish statements via the government’s new reporting service (as well as on their websites, as they do under the current rules).
• Penalties for non-compliance – Civil penalties for non-compliance will be considered.

Legislative changes will be introduced when parliamentary time allows. The government will also publish updated guidance, including best practice approaches to reporting. Further discussion of the proposed reforms is available here.