Out-Law News 2 min. read

UK government publishes modern slavery statement

The UK government has published a statement setting out how it is tackling modern slavery in its supply chains.

The UK said it was the first country in the world to publish such a report, which identifies how the government is seeking to assess the risk of modern slavery. Earlier last week the government also published guidance (167 page / 1.3MB) for safeguarding victims of modern slavery, outlining support and how organisations should identify potential victims.

The statement (29 page / 492KB PDF) outlines the steps the government took in 2019 to identify, prevent and mitigate modern slavery in its operations and supply chains. These steps included training for commercial staff involved in procurement, and the development of a tool to strengthen modern slavery due diligence.

The government said more than 1,000 organisations had used the new tool since March last year, and it had directly worked with over 400 suppliers on steps to make supply chains more resilient to modern slavery.

The report refers to central government procurement processes evaluating social value at award stage, with a minimum 10% weighting where relevant and appropriate. Social value policy outcomes will include reducing modern slavery risks, if this is relevant to the contract.

The government said it was focusing particularly on technology hardware and electronics, construction and service staff as these were the areas where the risk of modern slavery was highest for government departments. The statement revealed that the Crown Commercial Service was working with monitoring organisation Electronics Watch to monitor conditions for workers at factory level in its technology hardware supply chains.

Neil Carslaw of Pinsent Masons, the law firm behind Out-Law, who helps businesses comply with their obligations under the Modern Slavery Act, said: “The report flags the UK government’s approach to assessing and addressing modern slavery risk in its own procurement processes, and to promoting zero-tolerance of modern slavery internationally."

“It acts as a reminder of the progress made in compliance programs over the last five years, and the direction of travel through international frameworks and commitments,” Carslaw said.

“In particular, it flags ICT hardware and electronics, construction and facilities staff as the most ‘severe, salient and strategic’ risks. Reference is made to cabinet guidance which encourages public procurement teams to conduct modern slavery risk assessments and, during tenders, consider whether bidders have demonstrated that they manage and monitor supply chain slavery risk,” Carslaw said.

“It also flags a risk for companies that don’t comply with their section 54 transparency obligations of being excluded from public contracts, or being named and shamed by the Home Office,” he said.

Carslaw said the government aim of creating a registry of modern slavery statements in 2020/21 would help individual departments assess suppliers’ compliance with section 54 of the Modern Slavery Act 2015.

The UK government statement sets out a range of goals for the upcoming financial year to support individual ministerial departments. These include the appointment of anti-slavery advocates within each department, and support for departments to develop training, guidance and key performance indicators.

“Given that an objective of modern slavery statements is to show year on year improvement, the approach of government departments should continue to develop, as should the related enquiries made of government suppliers,” Carslaw said.

The government added that it would strengthen central risk identification and due diligence measures in 2020/21, by establishing cross-government working groups, and ensure departments implement changes such as reviewing their own policies, map suppliers’ supply chains, and begin risk assessments.

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