With 16 million of the estimated 40 million people currently in slavery conditions working within the private sector, it is vital that business plays its part in tackling modern slavery and human trafficking. As such, the private sector is one of my five priority areas and I have been working hard to ensure meaningful action by business.
The Modern Slavery Act requires all businesses with a turnover of £36 million or more and which provide goods and services in the UK to produce an annual statement explaining what they are doing to tackle modern slavery and human trafficking within their business. This is important work: UK businesses can use their buying power to drive responsible employment practices down through their supply chains, improving working conditions on a global scale.
However, corporate response to this requirement has been patchy at best. While some companies are showing leadership, others are producing generic statements with little substantive detail or failing to produce them at all. In 2017, 43 of the FTSE 100 failed to be compliant with the basic requirements of this legislation. It is unacceptable that such a large proportion of the biggest businesses in the UK are turning a blind eye to modern slavery and British law.
Scrutinising corporate compliance with section 54
As such, increased scrutiny is needed to ensure they comply in future years and to send a strong message to the rest of the market that this will not be tolerated. As noted previously, in December 2017 I wrote to 25 of the non-compliant FTSE 100 companies. I have received responses from around one third, all of which confirm that they have corrected their omissions and will take modern slavery more seriously in future. I commend them but am disappointed in the companies who did not respond. As such, those companies will soon receive further communication from my office which I hope will be in partnership with British asset managers who, as shareholders in those businesses, are deeply concerned about their lack of attention to this important manner.
Additionally, I have recently written to a number of FTSE 250 businesses who simply did not produce a modern slavery statement at all in 2017. I look forward to reading their explanations of this failure in due course. The research underpinning my engagement with FTSE-listed businesses has been provided by the Business and Human Rights Resource Centre, of whose assistance I am grateful.
Calling for a list of businesses which fall under section 54
In order to ensure adequate scrutiny is applied to companies’ modern slavery statements, it is important to know which businesses should be reporting. Whilst the ‘transparency in supply chains’ clause of the Act was landmark legislation, it failed to make provision for a list of all the companies which would fall under its purview. This makes it problematic to identify non-compliant companies and engage with them to ensure they play their part. My office has been investigating why the creation of such a list has not happened. It has researched potential routes to creating one, including via HMRC, Companies House and private sector databases. I am recommending that the ability to create this list is built into plans to digitise Companies House records. This is the most sensible way to ensure such a list can be publicly held and created annually. In the interim period before this is possible, I recommend that government buys in a list, as accurate as possible, from private sector businesses which can provide such data.
Raising corporate awareness of slavery
To complement action which adds scrutiny to corporate performance on modern slavery, I have been raising awareness of modern slavery in multiple business-related forums. This includes speaking at business events, such as to the UN Global Compact’s UK working group on modern slavery. My office has piloted partnering with the Chartered Institute of Procurement and Supply to provide joint presentations for procurement professionals on why this matters and how to address it within their work. In partnership with the Local Government Association, the ‘Modern Slavery: A Council Guide’ provides suggestions for local councils on how they can ensure their own supply chains are free from slavery and how they can utilise a range of legislative measures to encourage and regulate ethical working standards.
Additionally, we have worked with the Principles for Responsible Investment, the world’s leading organisation for promoting responsible investment practices and which has signatories totalling $60 trillion in assets under management. With them, we presented a joint expert webinar to inform asset managers about modern slavery, the Act and what actions companies should be taking.
Supporting sectoral initiatives
Whilst there are clear universal actions needed by companies across the market, sector-specific solutions are also important for tackling modern slavery. My office has been advising, engaging with and supporting a range of such initiatives. On fishing, a high risk sector, this has included advising the Seafood Business for Ocean Stewardship initiative and responding to the consultation by Seafish on its Responsible Fishing Scheme Standard, to which we advised the inclusion of the abolition of recruitment fees. On two further high risk industries, hospitality and construction, we have provided support and advice, such as on the Shiva Foundation’s report, Charting a Course for Collective Action: Addressing Slavery in the Hotel Industry and separately, on a forthcoming landmark report for the construction sector. Finally, on hand car washes, which have gained news headlines for labour exploitation and potential modern slavery, I have partnered with Nottingham University to embark on a new research project which you can read more about here. This will enable real, research-based insights to help understand and guide action on this concerning sector.
Ensuring slavery is high on global agendas
Of course, business is not just local but global. As such, it is vital to support international initiatives and ensure modern slavery is a topic high on the agenda of international discussions. I have been pleased to work with Unilever to ensure modern slavery is part of B20 discussions. The B20 ensures the voice of business is represented at the G20 and as such, is an important forum for keeping modern slavery high on the global agenda. Specifically, I have recommended that the B20 should support more country ratifications of the 2014 ILO Protocol on the 1930 Forced Labour Convention and the encouragement of the ‘Employer Pays Principle’, which aims to eradicate recruitment fees as a key enabling factor of debt bondage.
This is just some of the private sector work which I have been undertaking in recent months. I look forward to continuing this work, joining forces with businesses and their associations who wish to lead in the fight against this egregious abuse. It is unacceptable that slavery persists in the 21st century; with the help of business, we can ensure that it is ended.