In July 2019 the government launched a consultation, 'Transparency in supply chains', seeking views on proposed changes to transparency in supply chains reporting under the Modern Slavery Act 2015.
The government has now published its response to the consultation.
Section 54 of the Act contains an obligation on commercial organisations with an annual turnover of £36 million or more to publish an annual statement setting out the steps that they are taking to prevent modern slavery in their operations and supply chains. The government proposes to legislate for the six areas that slavery and trafficking statements should cover (currently there is a non-exhaustive list of information that an organisation "may" cover in the statement). Organisations that have taken no steps in a particular area will have to state this and will be encouraged to provide a reason why not. The obligation to provide a section 54 statement will be extended to public sector organisations that have a budget threshold of £36 million or more.
There is currently no prescribed statutory time limit on when the organisation must publish its Statement. The government is proposing to legislate to require organisations to meet a single reporting deadline, the intention being that organisations will report on the same 12-month period between April to March. The government also proposes to make it a requirement that the Statement be published on a government website (currently in development by the Home Office).
The government is also considering enforcement options for a failure to publish a Statement, alongside the development of a new enforcement body. There are no timings for any of these measures so it may be a while before they come into force.
