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Freshfields Sustainability

| 2 minutes read

The role of the private sector in tackling modern slavery cannot be underestimated, says the Independent Anti-Slavery Commissioner

The UK Independent Anti-Slavery Commissioner (IASC) highlights the important role that the private sector can play in addressing modern slavery, both in the UK and worldwide, in his Annual Report 2015-16 published on 12 October 2016.

The position of IASC was created by the Modern Slavery Act 2015 (MSA). The current commissioner, Kevin Hyland OBE, formerly head of the London Metropolitan Police Service’s Human Trafficking Unit, is the first to hold the post. The purpose of the annual report is to present achievements delivered under five priority areas identified in IASC’s Strategic Plan 2015-17, one of which is private sector engagement to encourage supply chain transparency and combat labour exploitation, and to outline priorities for the coming year.

What has been achieved so far?

The annual report sets out progress made in private sector engagement, including in the following areas:

First, ensuring that supply chains are not tainted by slavery. The IASC has been collaborating with the UK Government and its suppliers to encourage leadership by example. Consequently, the Cabinet Office has agreed to include a section on modern slavery expectations in their supplier code of conduct. The IASC has also been supporting the All Party Parliamentary Group on Modern Slavery and Human Trafficking to make sure there is a fit-for-purpose central repository for modern slavery statements.

Additionally, the IASC has been working with businesses, offering assistance to certain companies whose supply chains may have been tainted by slavery to ensure they respond appropriately. He has met with the big five supermarkets to discuss their modern slavery commitments and is supporting networks, such as the Consumer Goods Forum, in their lobbying efforts. The IASC has also been promoting publications that set out best practice, including writing a foreword for the Chartered Institute of Building’s reporton modern slavery, and disseminating Finance Against Trafficking’s report on Forced Labour, Human Trafficking and the FTSE 100.

Second, financial sector engagement. The IASC refers to the UK Government’s action plan for anti-money laundering and counter-terrorist finance, published in April 2016, that recognises the proceeds of crime from modern slavery as one of the most significant money laundering threats. The IASC has addressed banking professionals on the key role of financial institutions in tackling modern slavery through the Anti-Money Laundering Professional Forum and the European Bankers Alliance.

Third, targeted initiatives in sectors where slavery is likely to be prevalent, in particular in the fishing industry, by working with businesses, law enforcement and NGOs.

Fourth, combating labour exploitation in the UK. The IASC was involved in the UK Government consultation which led to the broadening of the powers of the Gangmasters Licensing Authority (a non-departmental public body in the UK whose purpose is to tackle labour exploitation), as it transforms into the Gangmasters and Labour Abuse Authority (GLAA), and in the creation of a new role of Director of Labour Market Enforcement.

Next steps

The IASC states the MSA is just the first step towards tackling modern slavery and that, although transparency is a means of creating accountability, it is not an end in itself.  The IASC is working to ensure that the MSA requirements are not simply seen as a tick box exercise, and that companies produce modern slavery statements that both comply with MSA obligations and demonstrate decisive action. The IASC will continue to promote the use of effective models to allow for easy scrutiny and comparison of modern slavery statements.

The IASC also plans to work closely with the new Director of Labour Market Enforcement and the reformed GLAA in preventing labour exploitation, and with government bodies, financial institutions, and researchers to improve the UK’s response to tackling the criminal proceeds of modern slavery.


human rights, human rights reporting, ruggie principles, labour rights, corporate accountability, csr, supply chain