Challenging the Tick Box Approach: A Review of the Modern Slavery Act

The UK Home Office is currently conducting an independent review of the Modern Slavery Act (2015) to ensure the legislation remains effective in tackling this terrible crime. STOP THE TRAFFIK submitted written evidence to this review, recommending changes to Section 54 of the Act which requires a business with a turnover in excess of £36 million to report annually on the steps they have taken to ensure that slavery and human trafficking are not taking place within their operations or in their supply chains.

Business risk analysis illustration showing buildings with targets on themAlthough some businesses who are leading in corporate social responsibility already treat modern slavery as a matter of compliance, too many companies only treat the issue as part of their marketing strategy. Addressing modern slavery should not be left to a minority, but should become a consistently practised norm of business operations. STOP THE TRAFFIK believes that a business culture which treats modern slavery prevention as a marketing technique will only ever commit to the easiest and lightest action possible, reducing effective due diligence to simply ticking a box.

To address this, STOP THE TRAFFIK recommends that the requirement to report annually is embedded into the Companies Act (2006). Not only would this improve business risk mitigation, it would symbolise a substantial step-up in global leadership for the UK and keep the country at the cutting edge of this issue.

STOP THE TRAFFIK is also concerned that the current Act does not clearly establish modern slavery within the framework of human rights and is therefore at risk of compartmentalising the issue. Separating modern slavery from human rights both undermines subsequent business mitigation and sends mixed messages to businesses.

In this regard, STOP THE TRAFFIK recommends that the Act explicitly promotes that prevention strategies are adopted into wider human rights due diligence policies. It is only through this holistic approach that victims will be provided with true restitution.

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