On 22nd May, the Home Office published this report of an independent review of the Modern Slavery Act 2015.  The review considered specific provisions in the Modern Slavery Act 2015: the role of the Independent Anti-Slavery Commissioner, transparency in supply chains, Independent Child Trafficking Advocates and legal application of the Modern Slavery Act.  It contains a number of recommendations.  For example, the Review considered how to ensure compliance and improve the quality of modern slavery statements produced by eligible companies.  Stakeholders were clear that the lack of clarity, guidance, monitoring and enforcement in modern slavery statements needed to be addressed to improve clarity and quality.  The report recommends that 6 areas of reporting currently recommended in guidance should be made mandatory; that the Government should set up a central repository for statements made by companies and required by the Act; the Independent Anti-Slavery Commissioner should monitor transparency; sanctions for non-compliance should be strengthened; and the Government should bring forward proposals for an enforcement body to enforce sanctions against non-compliant companies.  The report says requirements should be extended to the public sector and to the public procurement process; the Companies Act 2006 should be amended to include a requirement for companies to refer to their modern slavery statement in their annual reports; and that reporting requirements or to act when instances of slavery are found should be an offence under the Company Directors Disqualification Act 1986.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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