The U.K. government has published its 2018 U.K. Annual Report on Modern Slavery (the Report), providing a detailed overview of how U.K. companies have responded to modern slavery issues in the last year, since the introduction of the reporting requirement under the Modern Slavery Act 2015 (the Act).
Companies with a U.K. operation and revenues of over £36 million are required to publish a statement on their website within six months of their financial year-end about their approach to modern slavery. Modern slavery is an often hidden crime that includes slavery, servitude, forced and compulsory labour and human trafficking. Labour exploitation typically involves poor working conditions, extremely low pay and some form of coercion.
It is estimated that only 60 percent of in-scope companies have published a statement to date. The Home Office recently wrote to the CEOs of more than 17,000 companies that are required to publish this statement requesting that they do so (or produce an updated statement) and submit it to a specified transparency database. Failure to do so will result in being named and shamed on a list of noncompliant companies.
The Report acknowledges that the prevalence of modern slavery in the U.K. and abroad continues to be difficult to measure. However, some useful and reliable sources of data relating to modern slavery are considered. These include the referral of potential victims under the Act’s “duty to notify” provision and the number of modern slavery crimes reported to the police (although some of this data is limited to England and Wales only).
The Report identifies the following significant developments in the last year:
- Large companies are implementing and publishing the steps they are taking to identify, tackle and prevent modern slavery. In particular, there have been sector-led initiatives such as “Tech Against Trafficking,” in which technology companies and nongovernmental organisations have paired up to examine how technology can help eradicate modern slavery.
- An increase in enforcement action under the Act as a result of successful collaborative operations among a number of different resources (including Immigration Enforcement, Her Majesty’s Revenue and Customs and the U.K. police forces) led by the National Crime Agency. In 2017, 130 defendants were prosecuted — almost three times as many as in 2016.
- An increase in the availability of specialist and financial support and advocacy services to victims of modern slavery and human trafficking.
The U.K. government has commissioned an independent review of the Act that will consider whether it should be updated or strengthened in specific areas. This review is due to be published in March 2019.