Despite the introduction of the Modern Slavery Act 2015 (MSA) and the continuing efforts to raise awareness of the challenges of modern slavery in the UK, concerns remain over the lack of progress in tackling the problem and the Government’s efforts to drive business compliance with the annual reporting requirements.

In July 2018, the UK Home Affairs Committee launched an inquiry into modern slavery, calling for written evidence to assess what progress has been made since the introduction of the MSA in 2015 and what further action is necessary.

The committee is inviting written evidence on, but not limited to, the following:

  • how to increase understanding and reporting of modern slavery offences;
  • what success in tackling modern slavery would look like, and what benchmarks should be used to measure progress;
  • how the police and immigration system’s response to modern slavery offences could be improved; and
  • the current scale and nature of modern slavery.

The committee is accepting written submissions here. The deadline for submissions is Friday 7 September 2018.

This Government initiative reflects a growing desire to increase the focus on transparency through company reporting requirements. Indeed, the campaign group Focus on Labour Exploitation (FLEX), in its report Seeing through transparency: making corporate accountability work for workers, has recently published a ten-step action plan for governments to make sure that the interests of workers are central to efforts to tackle human trafficking and forced labour in global supply chains. Read the full report here. The proposals include:

  • requiring public agencies, as well as companies, to carry out risk assessments and reporting on the impact of their operations on workers in global supply chains;
  • developing specific transparency reporting criteria for companies and public agencies and reporting enforcement;
  • introducing ‘joint and several liability’ enabling workers to claim compensation or take legal action against lead companies and subcontractors; and
  • establishing market-wide labour inspectorates and resourcing them to proactively enforce labour laws.

The FLEX plan benefits from in-depth engagement with businesses, academics, trade unions and members of the public. Indeed, recent research suggests that company compliance with the annual reporting requirement is low. FLEX identified that when labour abuses and exploitation are left unchecked, low level abuses such as non-payment of the minimum wage can develop into severe exploitation.

FLEX identifies that governments need to make sure that the steps companies take to meet transparency obligations are both monitored and enforced. FLEX’s research finds that for annual reports to be useful, governments need to introduce more specific reporting requirements than is currently the case under the UK’s MSA. FLEX suggests that when companies are free to choose what information to disclose, company practices that drive modern slavery may go unnoticed. It follows that we may well see more prescription on the contents of annual reports. Arguably, this will give the transparency provisions sharper teeth.