The government has now created its own central register for modern slavery statements, in line with one of the commitments it made in response to its consultation on how it would enhance reporting requirements on organisations who need to publish a statement.
Currently, statements published in accordance with the requirements of section 54 of the Modern Slavery Act are only required to be published on an organisation’s website with a link to the statement in a “prominent place”. Many statements are already published on existing registers compiled by interested stakeholder organisations such as the Business & Human Resource Centre. In the future the government will be able to use its own register to monitor compliance, and public, investors and consumers will be able to search for statements and scrutinise and compare the steps that different organisations have taken to tackle issues of modern slavery and human trafficking in their business and supply chain. You can search the register here.
The intention is that it will be mandatory for organisations to submit their statement to the registry as part of the proposed changes to strengthen the reporting requirements of the Act. However, as these measures require legislative change organisations are currently encouraged to submit their statement on a voluntary basis. Further details on how to submit your statement can be accessed here. At present only modern slavery statements relating to government bodies have been added to the new register although it is anticipated that organisations will wish to add their statement to reflect their compliance in this area, particularly if they engage with government bodies on procurement matters.
As we highlighted in our Law-Now following the government’s response to the consultation on proposed changes to the requirements for transparency under the Modern Slavery Act, this is an area that the government continues to focus on. It also goes hand-in-hand with the general increase in focus on Environment, Social and Governance (ESG) issues being the central factors in measuring the sustainability and societal impact of an investment in a company or business.
Organisations should consider what changes are required to their internal processes and reporting systems to cope with the proposed enhanced requirements in relation to modern slavery statements. Whilst the changes are proposed to come in ‘when Parliamentary time allows’ it is clear that the government is pushing forward with the commitments it made in its response to the consultation.