Hot on the heels of Jeremy Nixon’s article on the Modern Slavery Act 2015 (MSA) and the reporting duties it imposes on businesses, Thrings solicitor Andrew Strong recently attended a fascinating seminar entitled “The Impact of the UK Modern Slavery on Your Business.”
Hosted by Thomson Reuters at its Canary Wharf offices, a packed auditorium heard an interesting speech from Kevin Hyland OBE, the UK’s first Anti-Slavery Commissioner, on his role and the outlook for the eradication of modern slavery around the globe. This was followed by a panel debate and Q&A session with some of the leading thinkers in this area in the legal, commercial and NGO sectors.
The key messages arising from this seminar which we would recommend that clients take into consideration, whether or not they are currently covered by the reporting obligations of the MSA, are:
Beyond the legal aspects, combatting modern slavery is an ethical question. Those businesses which do not engage in this question because they are not obliged to risk being judged in the court of public opinion;
As public awareness of this matter and the legislative steps taken to combat it increases, so will the pressure on businesses to take action. The sooner businesses take steps to do something and are seen to be doing something (e.g. by publishing the annual report, even where not legally required to do so), the quicker they will understand what is involved and the better their reputation will be;
Businesses need to be, and need to encourage their staff to be, wedded to the idea of combatting modern slavery in their supply chains. While it may be difficult to influence the furthest reaches of the supply chain, businesses can use their influence over their immediate suppliers, for example, to encourage a trickle down effect;
It is likely that there will be further legislative developments across the EU on this question. To the extent that UK businesses are not currently covered by the reporting requirements under the MSA, they soon might be by virtue of legislation covering their group companies.
We will write again with further insights into the impact of the MSA on businesses as the first round of reporting takes hold.