This autumn the UK government issued its “2017 Annual Report on Modern Slavery”, which can be found here: https://www.gov.uk/government/publications/2017-uk-annual-report-on-modern-slavery
Key highlights of the yearly report about what the UK government has done to combat modern slavery and human trafficking are as follows:
- In 2016, 3,804 potential victims (of which around a third were children) were referred to the UK’s “National Referral Mechanism”, which was a 16% increase on 2015 – potential victims were reported to originate from 108 countries the most common country of origin for adult potential victims being Albania and the most common country of origin for those exploited as children being the UK;
- Up to March 2017 2,255 modern slavery offences were reported to the police in England and Wales, which was an increase of 159% on the previous year;
- Under the UK’s so-called “four P’s” strategy the following took place: Pursue – significant funding has been provided to UK law enforcement to transform the response to modern slavery; Prevent – the UK Government has focused on developing the evidence base on modern slavery to inform prevention activity; Protect – the compliance disclosure requirements (see below) resulted in thousands of slavery statements being published, and, the UK Government launched a new “Business Against Slavery” forum to bring together a group of committed CEOs from leading businesses to help identify how best to drive up standards and accelerate progress in tackling modern slavery in supply chains; Prepare – the UK Government continued to fund specialist support and accommodation for adult victims of modern slavery for a minimum reflection and recovery period of 45 days.
Under the UK Modern Slavery Act 2015 compliance disclosure requirements an organization with UK £36 million turnover that sells goods or services in the UK is required to annually publish a slavery statement demonstrating what they are doing to ensure that there is no slavery or human trafficking in the business or the supply-chain, which also applies to organizations based outside the UK selling goods and services into the UK; this compliance obligation has been in force since 29 October 2015 and many organizations who fall under it have already previously published their first statement. As the UK’s recently updated guidance on the disclosure requirements states, organizations must “paint a detailed picture” of all the steps that they have taken.
Those organizations whose financial end-of-year is this December 2017 and who meet the criteria to publish a slavery statement will be required to publish a statement to cover the period of January-December 2017, which they will have to do by the end of June 2018. If this is the second statement it will have to show progress on the first one. When putting together the statement organizations will need to take on board the UK’s revised guidance, which we have written about here: http://www.corderycompliance.com/uk-modern-slavery-guidance-updated/
By way of reminder, the UK is also currently in the process of amending the UK Modern Slavery Act 2015 with a view to giving modern slavery compliance enforcement more teeth, which we have written about here: http://www.corderycompliance.com/update-on-proposal-to-amend-modern-slavery-act-2015/
Training is a vital part of any compliance, which is equally true of modern slavery compliance. Crucially, employees and suppliers need to know how to spot the signs that modern slavery may be taking place, which we have made a short film about that can be found here: http://www.corderycompliance.com/spotting-the-signs-of-modern-slavery/
For other articles that we have written about modern slavery compliance please see here: http://www.corderycompliance.com/category/modern-slavery/
For more information please contact André Bywater or Jonathan Armstrong who are commercial lawyers with Cordery in London where their focus is on compliance issues.
|Jonathan Armstrong, Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH||André Bywater, Cordery, Lexis House, 30 Farringdon Street, London, EC4A 4HH|
|Office: +44 (0)207 075 1784||Office: +44 (0)207 075 1785|