My presentation to small businesses at the Modern Slavery Partnership (Hampshire and Isle of Wight)(26 Sept) focused on disclosure statements that corporates are obliged to make under the Modern Slavery Act 2015 and upon the cascading effect of compliance on smaller businesses in the supply chain. As examples, I provided the statements of Ford, Intel and Chivas to show how well these had been considered and drafted and the Business & Human Rights Resource Centre has recently highlighted Ford, Intel and paving and tiling specialists Marshalls as among the best performers as companies that have taken the issue of modern slavery seriously and have done detailed due diligence. However in many cases it seems companies have rushed out statements with little meaningful content. The Business & Human Rights Resource Centre’s research says that companies appear not to have grasped the “spirit of the act”, and have issued declarations that are based on a common template and use identical language.
Marilyn Croser, director of CORE (the UK civil society coalition on corporate accountability), which contributed to the centre’s work, says the statements show in many cases inadequate engagement with the issues and with the basics of the law. They may also reflect a degree of first time nerves. The “requirement is new so companies will be cautious about exposing themselves and releasing more information than others in their sector”, Croser adds.
As discussed at the Modern Slavery Partnership Forum, there is a belief that due to the current lack of hard penalties under the Modern Slavery Act for non-compliance with the reporting requirements, many companies are not currently understanding the significance of the statements and may have a misguided belief that they are not over-exposed to the risk of slavery in their supply chains, despite the growing evidence of serious human rights problems for many sectors. Any detrimental effect relates to reputational and brand harm, which are relevant and important but are mostly led by public pressure.
That being said, a number of the small businesses to whom I was speaking last Tuesday did seem to be taking their responsibilities very seriously and were concerned about their own suppliers and how best they could tackle modern slavery in their supply chain, notwithstanding a lack of resource and budget. This is certainly a positive step and these small businesses should be commended for this.