Independent anti-slavery commissioner publishes strategic plan including engagement on supply chain transparency

Independent anti-slavery commissioner publishes strategic plan including engagement on supply chain transparency


Author: Ron Reid

Applies to: UK wide

The UK has its first Independent anti-slavery commissioner, Kevin Hyland OBE.

Mr Hyland has shared his strategic vision to 'make the UK a more hostile environment for traffickers and slave masters to operate in and to develop strategies to address the demand that contributes to modern slavery'.


Mr Hyland identified key priorities:

  1. Victim identification and care
  2. Driving an improved law enforcement and criminal justice response
  3. Promoting best practice in partnership working including between statutory agencies and the private sector
  4. Private sector engagement to encourage supply chain transparency and combat labour exploitation
  5. International collaboration

This briefing focuses on the fourth priority in respect of which Mr Hyland wants 'to work in collaboration with businesses across the UK to ensure they are doing everything they can to make certain their supply chains are not tainted by slavery'.

'Effectual transparency reporting'

Mr Hyland has stated that he will engage with the private sector to promote policies to ensure that the supply chains are free from slavery and to encourage 'effectual transparency reporting'. He is developing 'models of best practice' to ensure supply chains are slavery proof as well as increasing transparency.

The competitive commercial market place has placed an increasing demand for cheap products and cheap labour. Businesses and consumers want more for less. The effect of such demands has been to increase the prevalence of slavery, forced or coerced labour (including debt bondage) in global supply chains as suppliers and businesses seek to maximise profitability whilst keeping prices low.

The notion of slavery in all its forms as a human rights abuse has long been enshrined in International Law. In the UK, Section 54 of the Modern Slavery Act will come into force later this month. We have previously reported on the scope of that Section, the impact for business and the steps that can be taken to prepare. Statutory guidance in respect of Section 54 will be available to supplement the provisions.

1. Achieving priorities

Mr Hyland has identified a number of ways his priority in respect of supply chain transparency can be achieved. The overriding message is active engagement with the private sector. There are a number of ways this can be achieved:

Ensuring supply chains are not tainted by slavery

Through working with trade bodies and businesses, best practice in ethical labour practices and supply chains should be identified, promoted and encouraged.

Understanding of the transparency in the supply chain provisions within the Modern Slavery Act should be promoted. Businesses should be encouraged to adopt best practice in policy responses and reporting.

Identifying sectors where slavery is likely to be prevalent and developing targeted initiatives in those sectors. By way of example, Mr Hyland has been working with Seafish (a non-departmental public body) in order to raise standards across the seafood industry and tackle slavery within it.

Promoting awareness of the issue by working in partnership with the transport sector including airlines and other transport networks.

Police chief constables and CEOs of companies in at-risk industries will be encouraged to work together on the issue of modern slavery.

Developing 'effective prevention models' both in the UK and abroad in conjunction with the Gangmasters Licensing Authority.

Combating labour exploitation in the UK

There are a number of inspectorates which carry out work in respect of labour exploitation. Mr Hyland believes this can be built on through recommending improved pro-active labour inspections with the victim at the centre. The focus should be on key sectors where exploitation is taking place.

The Gangmasters Licensing Authority has a victim centred model which should be promoted across the European Union and internationally.

Financial sector engagement

The development of tools and initiatives within the financial sector to tackle 'the unwitting facilitation' crime comprising modern slavery will be encouraged.

2. How will success be measured?

Mr Hyland is keen to track and evaluate progress the business community makes in eradicating modern slavery from supply chains. His report identifies a number of ways in which it will be possible to know improvements are being made:

  • Businesses will comply with the requirements of the Section 54 provisions
  • Investigations into modern slavery crime will take place arising out of suspicious activity reports from financial institutions, including banks.
  • The financial sector will partner with statutory agencies to target "illicit money flows"
  • Effective prevention partnerships will be developed between CEOs and chief constables
  • There will be establishment and wide-spread adoption of best practice models on business and supply chain transparency

3. What next for business?

Mr Hyland regards modern slavery as 'both an extremely serious crime and a grave violation of human rights and human dignity'. He is determined to 'identify those failing to deliver' in respect of best practice.

Businesses caught by the provisions or who supply goods or services to those who are, should prepare now by deciding what approach they are going to take.

If you are in any doubt about what to do, Ron Reid or a member of our specialist Regulatory team is here to help.