July 9, 2020

Boards cannot afford to overlook the Modern Slavery Act

The behaviours that the Board display, individually as directors and collectively as the Board, set the tone from the top. The Board should take an active role to adopt a robust anti-slavery stance at the highest level, and communicate this both internally and externally.

What is the Modern Slavery Act 2015?

The Modern Slavery Act 2015 (Act) introduced changes that focus on increasing transparency in supply chains.

The Act emphasises the urgent need for Boards to take appropriate and proportionate action to ensure slavery and human trafficking is not taking place in the Company’s business or its supply chains.

The recent headlines surrounding Boohoo, highlights that directors are exposing themselves to the very real danger of breaking the law if they do not keep a close eye on their supply-chain arrangements.

Action Points

As part of the Board’s ongoing monitoring and oversight responsibilities, directors should:

  • continue to monitor, discuss and evaluate their supply chain policies and procedures to ensure that they are sufficiently robust to mitigate the risk of modern slavery occurring in their business and supply chains
  • conduct due diligence and regular audits on suppliers within the Company’s supply chains
  • undertake a review of existing supplier arrangements, particularly in high risk sectors or jurisdictions
  • adopt a code of conduct to act to minimise the risk of slavery and human trafficking occurring in the business and in its supply chains
  • ensure consistent messaging of the Company's modern slavery policy is communicated throughout the Company's supply chain.

How can we help?

We are experienced in advising Boards on their responsibilities and obligations under the Modern Slavery Act 2015. If you have any questions, please get in touch with our Corporate Team.

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