Tougher measures to tackle modern slavery in the supply chain

The Home Office has recently published the government’s response to the transparency in supply chains consultation. It sets out how the government will strengthen the transparency requirements in the Modern Slavery Act 2015 to tackle modern slavery in the supply chain.

This marks a major milestone for increasing transparency in public sector supply chains, following the publication of the world’s first government modern slavery statement in March this year.  

Following strong support from respondents across business, the public sector and civil society, the consultation response commits to an ambitious package of new measures to strengthen and future-proof the Modern Slavery Act’s transparency legislation.

These include:

1. harnessing the spending power of the public sector to drive up labour standards in supply chains by extending the transparency requirement to public bodies with a budget of £36 million or more
2. introducing mandatory reporting topics that statements must cover, such as due diligence, to incentivise better quality and more detailed reporting
3. requiring modern slavery statements to be published annually on the new government reporting service by a single reporting deadline, to encourage compliance and empower investors, consumers and civil society to monitor progress and scrutinise action taken

Point 1 will apply to England and Wales. Scotland will consult separately on this. Points 2 and 3 will cover England, Wales and Scotland. Northern Ireland will consult separately on all changes.

The government is also considering options for civil penalties in line with the development of the single enforcement body for employment rights, a manifesto commitment led by the Department for Business, Energy and Industrial Strategy.

These measures will require amendments to legislation and will be introduced as soon as parliamentary time allows.

In the meantime, significant work is currently underway to develop the new government-run registry for modern slavery statements, which is due to launch in early 2021.

How is CCS tackling modern slavery in the supply chain?

We have been working in close partnership with the Home Office and Cabinet Office since 2016 to develop an approach to managing modern slavery risk in public sector procurement.

This includes the development of the ‘Tackling modern slavery in government supply chains’ procurement policy note and guidance, as well as a dedicated Modern Slavery Assessment Tool (MSAT), which enables all public sector buyers to assess their supplier’s modern slavery risks.

In 2019, it was agreed that CCS would play a key role in supporting the government’s new modern slavery statement by risk assessing its existing framework contracts using the MSAT tool.

26 frameworks were identified as being at potentially high or medium risk of modern slavery occurring. We published a list of those high and medium risk framework contracts on our website, to inform our customers of what we are doing to prevent modern slavery.

286 suppliers working under these frameworks were asked to complete a modern slavery assessment, using the MSAT tool. Follow-up analysis and discussions are taking place with all suppliers who returned a high risk score. Improvement plans are being agreed and put in place to ensure that known risks are fully addressed and mitigated.

A full programme of internal training is also being rolled out across CCS to all of our commercial agreement managers, so they are better prepared to identify and prevent modern slavery risks in our new frameworks.

Empowering you to make better procurement decisions

You can learn more about the role of CCS in our on-demand webinar.

You might also find our recent blog about modern slavery in the workforce helpful.