‘Building on the Modern Slavery Bill: Going Beyond Transparency’

We are pleased to announce the launch of our report, ‘Building on the Modern Slavery Bill: Going Beyond Transparency.’ 

The report can be downloaded by clicking on the following link: Supply Without Chains ‘Building on the MSB’.

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In June 2014, the UK Modern Slavery Bill began its passage through Parliament. Part 6 of the Bill, ‘Transparency in supply chains’, introduces a requirement for companies above a certain size to report on their efforts made, if any, to remove forced labour practices from their supply chains. This means that a company can simply report that they are making no such efforts, and still be compliant with the law.

The report seeks to build on Part 6 of the Bill by making recommendations for further action beyond the legislative requirements.  The recommendations we make are the key issues that have arisen throughout our research as the most important and feasible ways of ensuring that companies’ transparency statements are as effective as possible.

This provision in Part 6 adopts the model set out in the California Transparency in Supply Chains Act 2010. We have spoken to US based organisations who have worked closely on the implementation and execution of the California Act in order to learn crucial lessons on what has been a success and what could have been done differently.  This has enabled us to critically evaluate the best ways to supplement the UK transparency provision so that it has a real world impact on eradicating forced labour and slavery in supply chains.

In our report, we propose mechanisms in four areas to reinforce Part 6:

  • Section 1 addresses the issue of enforcement and regulation of company practice. We suggest campaigning directed at increasing the remit and funding of the Independent Anti-Slavery Commissioner in order for him to have the role of monitoring and enforcing companies’ best practice, and the expansion of the role of the GLA to other at risk sectors;
  • Section 2 addresses the problem of the complexity of supply chains. In order to make a comprehensive and accurate transparency statement, companies need to know the labour practices occurring at all stages of their supply chains. We will propose a focus on the quality of independent auditing, training programmes and effective regulation to ensure that companies can make sufficiently detailed statements;
  • Section 3 suggests the use of websites and social media to support the transparency statements. We will suggest a two-pronged approach to media platforms, developed by private voluntary initiatives. The first focuses on business engagement, and the second takes a consumer targeted approach;
  • Section 4 makes suggestions of minimum criteria for the Governmental Guidance that is to be published to supplement Part 6.

The report is targeted at those developing ways of supplementing the legislation and ensuring it is of maximum impact. Our aim is to support a coordinated effort involving civil society organisations, consumers and Parliament itself.

We welcome any comments you may have on the report. Do not hesitate to contact us at supplywithoutchains@gmail.com for further queries or comments.

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‘Building on the Modern Slavery Bill: Going Beyond Transparency’

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