Complying with the Modern Slavery Act is easy…
isn’t it?
By Helen Carter

Ever since the launch of the Modern Slavery Act 2015, NGOs and other interested stakeholders have voiced their disappointment at business responses to Section 54 requirements. Specifically, the growing frustration is that businesses have not responded more comprehensively, or with any commitment to the issue of compliance with the Modern Slavery Act..

The disillusionment over the lack of statement in some cases, or poor responses in others, is clear: many businesses have been slow on the uptake and are reluctant to investigate slavery issues in their supply chain in any substantial way.

Working in this field for the last five years, and being a procurement professional by trade, I see the argument from both sides of the table.

The unspoken problem

It is, without a doubt, reprehensible that anyone in today’s society should be subject to any form of slavery. I find it personally alarming to consider that whilst you go about your day, your consumption pattern will have somehow contributed to global slavery in varying degrees. Through delivering engagement events and workshops in the Supply Chain Sustainability School, and discussing issues with organisations up and down the tiers, I have yet to come across anyone who has failed to be shocked and appalled by what is happening, not only in developing nations, but in nations like ours (the UK), that should really know better.

When the Act was launched, there was estimated to be 13,000 victims of slavery in the world; now today, that estimate is about 136,000. People argue over the exact figures and methods of calculation, however the one thing that everyone can agree on is that there are considerably more victims than we thought. Not only that, we prove to be badly equipped to support victim found – whether it be because of a poorly-funded law enforcement, an insufficient support system for victims, or a lack of understanding or due diligence systems within businesses.

Recently, over a coffee with someone from the Gangmasters and Labour Abuse Authority (GLAA), they said it is mad we are still at ‘awareness stage’ so many years after the Act was first launched, with no real concrete or effective activity being undertaken in business. In fact, Dame Sara Thornton (the new Anti-Slavery Commissioner) recently called for the ‘Blue Planet Effect’ to be replicated in relation to modern slavery.

Whilst there has been no major television series highlighting the slavery issue, BBC’s Panorama did dedicate an episode to The Hunt for Britain’s Slave Gangs and the show The Prosecutors shone a spotlight on a nail bar case last year.  They did not however, generate anywhere near the interest of the orangutan story.  And there lies the problem: As humans we are willing to defend those that cannot defend themselves (namely animals) but assume that people will always have a choice and therefore demand less of our sympathy. If you have not already seen the Panorama expose, then I recommend you watch it and hear from victims who were vulnerable, felt they had no choice, and in some cases, were not able to defend themselves, either.

So, if compliance is easy in relation to publishing a modern slavery statement (there are only six steps to compliance) and people are appalled at the lack of compliance, why are we still not getting the business traction that the Act was meant to inspire?

Confusion and conflicting priorities

The harsh reality is, the world is in a state of chaos, with everyone pointing the finger at globalisation and consumerism, or blaming the business world whilst expecting them to solve it all. Although there is some element of truth in that painted picture, the reality is that most management in many organisations are trying to keep their businesses going. Not only that, but doing this whilst tackling climate change, supporting ecology, filling the skills gap, addressing the increasingly complex diversity environment, supporting initiatives in relation to plastics and waste, as well as a multitude of other sustainability challenges that can confuse, conflict and challenge any business operations.

How do we change the narrative?

I could give you a long list of mechanical activities to undertake to tackle the issue, but there are a number of those lists going around, and experience shows that if your rely on mechanical audit-driven activities alone, they will not address the issue effectively. So, here’s my advice:

  • Firstly, don’t wait for legislation. The last round of consultation has been undertaken on the Act, specifically Section 54, and whilst they are considering assimilation with elements of the Australian Act – that is, financially penalising any non-compliant organisations and tightening up the reporting and statement requirements – the reality is that with Brexit looming, if businesses are inconvenienced in the eyes of the politicians, they will resist anything substantial.
  • Secondly, accept that you are not going to eradicate slavery in your lifetime. Stop with the policy and statement quotes such as ‘no slavery in our supply chain, we have zero tolerance towards slavery’. So many businesses do this, and no-one can eradicate slavery from their supply chains and claim this with any certainty. That does not mean that you do nothing, but you must slowly eliminate the risks you can control, and take a longer, more pragmatic approach to investment in your supply chain. As a business, you have an element of responsibility for the demand you generate through your supply chain – take that seriously, not flippantly.
  • Be an organisation who cares about its people. Slavery is a by-product of poor labour standards and human right practices, so the simplest thing you can start to do is to treat your own people with fairness and consideration. The GLAA Construction Protocol has launched a free induction pack that can be used by anyone in the construction industry, branded “Are you alright?”. You can audit your sites, audit your suppliers or check passports, but nothing replaces good old human observation and connection.
  • Commit to a long journey. This is not about doing the bare minimum to produce a statement every year, this is about getting to grips with your business and figuring out how to work better with your supply chain to address challenges they may be experiencing.
  • Don’t be afraid of collaboration – even with the competition. As businesses you can take steps but sometimes this is about working with other organisations and challenging the status quo. You may even get some ideas of sharing best practice with other industries.
  • Be brave. Sometimes when you look at why slavery can happen in supply chains, it is as simple as incorrect procurement models, bad planning, poor client relations or even a lack of understanding within your own organisation. These failures result, not only in increased slavery risk, but can also be traced back to any number of poor organisational performance issues you may be experiencing. So be prepared to look at improving the way your business operates.

Can it work?

Create a more intelligent conversation in your organisation today: tie in anti-slavery activities and commitments with other people issues. Stop looking at modern slavery as purely compliance, but as the result of poor organisational practices and lack of investment in what could be your most important asset – your people, both within your organisation and your supply chain.

As part of the work within the Supply Chain Sustainability School, we recognise the need for a more intelligent conversation in regards to people, and so the School will launch its People Matter Charter in January 2020, aiming to start the journey towards better conditions for all people, up and down supply chains across the construction industry.  The Charter will address a conflicting landscape in relation to people issues within businesses, and provide a support mechanism to any member of the supply chain who wants to get better at attracting, retaining and supporting their workforce – which will in turn, hopefully make conditions for slavery a little harder to thrive.


Helen will be debating these issues on the “Transparency Session Panel” at the Responsible & Ethical Leadership in Global Supply Chains Conference on 6 November in central London. For further information and to register, visit

Helen Carter

For more information

Helen Carter, Lead Consultant

Read more about Helen here.

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