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Plans to Strengthen the Modern Slavery Act

The Government has recently published its response to consultation on transparency in supply chains, setting out as it does proposals to strength the reporting requirements under the Modern Slavery Act 2015.

Under the new rules, particular changes of note include:

  • Modern slavery statements must cover a number of defined areas, including the obligation of ensuring that there is training on modern slavery and human trafficking within the business;
  • A uniform reporting period of 1 April to 31 April, with a single reporting deadline of 30 September;
  • Statements to be published via the Government’s new reporting service;
  • Reporting requirements have been extended to public bodies with a budget of £36,000,000 or more, being the current threshold for commercial organisations;
  • The introduction of new civil penalties for non-compliance. We are expecting the government to release more detailed guidance regarding these new legislative changes at some point before the end of 2020, but there is a chance this may be delayed due to COVID-19 issues.

Accordingly, companies should review the contents of their current modern slavery statements in light of these proposed changes particularly those reporting areas that are set to become mandatory.

Will the scourge of modern slavery (not least in our public bodies) finally be defeated?  Time will tell.