Over the last month, the Home Office has written directly to the chief executives of 17,000 businesses telling them to open up about modern slavery in their supply chains, or risk being named and shamed.

The letter requests that companies register on the Modern Slavery Contact Database, publish up to date modern slavery statements by 31 March 2019 and gives some high level guidance of the minimum requirements for the statement.

The Home Office estimates that only 60% of companies in scope have published a statement. Moreover, many of those statements are of poor quality or fail to meet the basic legal requirements.

Modern Slavery Contact Database

The Home Office requests that companies have a nominated contact register on its Modern Slavery Contact Database as the Home Office plans to use this as a means to distribute material such as updated statutory guidance on reporting and best practice case studies.

Publication Date

The letter requests that companies publish their up to date modern slavery statement by 31 March 2019. After that date, if a company has not published or its statement is non-compliant the company risks being named and shamed on the non-complaint list.

The Modern Slavery Act does not contain a publication due date but indicates that companies should publish their statements as soon as possible after the end of their fiscal year and they are expected to have published within six months of their year-end. It is important to note that companies are required to publish a statement every year, setting out what they have done over the previous 12 months in relation to tackling modern slavery. It is not sufficient to have published one statement when the Act was introduced and consider your obligations fulfilled.

The letter also recommends voluntarily adding your statement to the Transparency in Supply Chains and the Modern Slavery Registry websites. These lists make it easier for the public to access modern slavery statements and ascertain whether a company has complied with their reporting obligations.

Guidance on statement content

The letter is consistent with the Modern Slavery Act and previous Home Office guidance. It also indicates that group statements published by parent entities should state the entities covered by the statement. To recap, businesses with a turnover of more than £36 million must publish a Modern Slavery Statement setting out the steps that the business has taken to stop modern slavery and forced labour practices occurring in their business and supply chains. Best practice is to include detail on:

·       The structure of the business and supply chains;

·       Its policies on modern slavery;

·       Training;

·       Risk assessment;

·       Due diligence; and

·       Measuring effectiveness.