Modern Slavery Act – shining a light

Over a decade on from the Gangmasters (Licensing) Act 2004, we now welcome the Modern Slavery Act 2015 and its requirements for transparency in supply chains. Working for IOSH, I first became involved in proposals for gangmasters licensing following the tragic death of 23 cockle pickers in Morecombe Bay in 2004. Of course, we fully supported licensing and have called for it to be extended to cover other sectors too, such as construction. And my subsequent involvement with the development of the Modern Slavery Act came through IOSH’s work with cross-party politicians following the 2013 Rana Plaza disaster that tragically claimed over 1,100 lives. Once again, we fully supported the need for new legislation and new disclosure requirements.

Shockingly, there are an estimated 36 million people enslaved across our globe. Modern slavery has been found in all 167 countries ranked by The Global Slavery Index in 2014, including in the UK, which ranked 149th. The UK Home Office estimate there were between 10-13,000 potential victims in the UK in 2013. So IOSH welcomes the UK’s world-leading Act and the new requirements for disclosures on anti-slavery measures and supply chains. This transparency requirement is absolutely critical, given worrying CIPS-commissioned research which estimated that 11% of business leaders with supply chains thought it likely that modern slavery was already in them. More recently, the CIOB report Modern Slavery: The dark side of construction highlighted human exploitation in both the developed and developing world, including on UK construction sites. The need to improve transparency was the theme of a recent joint-IOSH event in the House of Lords.

Following my call for member comments, IOSH took part in the Home Office consultation on anti-slavery disclosures in May. In our response, we recommended the use of the UN Guiding Principles Reporting Framework and stressed the importance of data that was meaningful and comparable. We also urged companies that fall below any reporting threshold to voluntarily disclose. Last week, the Government published its analysis, the turnover threshold, and what the next steps will be. The new Act brings a requirement for businesses with a certain turnover to disclose what they’re doing to ensure their business and supply chains are free of modern slavery and human trafficking. Regulations setting an annual turnover threshold at £36 million are now expected by October 2015, together with statutory guidance. The Government has said that it will take stakeholder feedback into account in producing this guidance.

Importantly, the Act also requires the Secretary of State to publish a paper on the role of the Gangmasters Licensing Authority by March 2016 and to consult on the paper. This is something we warmly welcome and I look forward to the opportunity of engaging our members in progressing this, with a view to finally extending licensing to construction and other sectors.

Modern slavery and human trafficking are abhorrent and lead to untold suffering, injury, illness and death – we need to use the new Act to shine much-needed light on it and ensure that no one is ever out of sight, out of mind.