Home Office consultation on transparency in supply chains – Law Society response

The proposals

The Modern Slavery Act 2015 made the UK the first country in the world to require organisations to publicly report on the steps that they are taking to prevent modern slavery in their operations and supply chains.

In July 2018, the home secretary commissioned the independent review of the Modern Slavery Act 2015. We made recommendations to the review.

The final review report was published on 22 May 2019, recommending measures such as:

• improving reporting quality
• clarifying the scope of organisations required to report

In response, the government has committed to strengthening the act’s transparency provisions.

This consultation aims to gather views on measures designed to enhance the impact of transparency.

Proposals include:

• a single reporting deadline
• mandating areas to be reported on by organisations
• extending the requirement to report to public sector organisations

Our view

We welcomed this consultation and the proposals within, having previously contributed to the independent review of the Modern Slavery Act 2015.

A number of our recommendations were reflected in the review team’s final report, and were included as proposals in this consultation.

We worked with the Human Rights Committee to give opinions on the proposals and information about our own modern slavery statement, which is published as a group statement by the Law Society Group.

We made several recommendations, including that:

• the reporting requirements should be extended to the public sector, especially to organisations that have a turnover over £36 million
• the Home Office should create a publicly available electronic registry of the companies captured by the act, and make sure this is adequate, up to date and checked annually
• a range of sanctions should be created to make sure companies comply with the act, such as financial sanctions

We recommended that companies should report on these six areas suggested by the act:

• structure and supply chains
• policies in relation to slavery and human trafficking
• due diligence
• risk assessment
• actions taken to reduce modern slavery
• training on modern slavery

Next steps

The government responded to this consultation in September 2020.

Read the government's response to its consultation on transparency in supply chains

We're pleased that the government intends to take forward the majority of our recommendations, including:

• making it a requirement for businesses to report on all six areas outlined in the act
• requiring public sector organisations with a budget of over £36 million to submit modern slavery reports
• creating a central, government-run database where statements submitted under the act will be published
• considering further enforcement options to improve compliance

The government has said it will make these changes to the Modern Slavery Act 2015 when parliamentary time allows.