It has been just over six months since I left the Independent Anti-Slavery Commissioner’s (IASC) office to join hard landscaping manufacturer Marshalls. The move from a public to a private sector – from policy to management - has been eye-opening. Previously I was reading and commenting on other people’s modern slavery statements across various industries. Now I have to write ours.
This has forced me to descend from my bird’s eye view – scanning the horizon for trends and best practice – and experience the micro, day-to-day challenge of working in a team to evidence our journey for ratings agencies, clients, investors and our own modern slavery statement.
Along with many in my position, I’m ever more conscious of the changing requirements of modern slavery reporting. The government has long been committed to tightening up section 54 of the Modern Slavery Act of 2015 and tabled its intention in the Queen’s speech of May 2022. Much has happened since then, not least the accession of a new monarch the appointing of two prime ministers. Nevertheless, the direction of travel is clear.
Businesses that fall under the scope of the act will have to cover specific topics in their statements (these are currently recommended in the government’s statutory guidance). There will be a single reporting deadline of 30 September. And there will be a legal obligation to link statements directly to the government’s modern slavery registry. For us, this is not too much of a stretch – like many responsible businesses, Marshalls’ statement already covers recommended areas, including its policies, its risk assessment processes and training of staff. We also voluntarily link our statement to the registry.
Regardless of when and how this legislation comes into force, there are other forces pushing organisations to go further and disclose more.
One of the last projects that I was involved with at the IASC office was a collaborative study with the Financial Reporting Council (FRC) and Lancaster University. This looked at the modern slavery reporting practices of 100 major companies, analysing and comparing the modern slavery statements with annual reports. The text of each document was assessed against an ethical framework developed by the Business and Human Rights Resource Centre.
The results of research echoed other studies and anecdotal findings: companies tend to be more confident when talking about policies and procedures. For example, 54% said that they assessed forced labour or modern slavery risks before signing contracts. But in terms of closer engagement, only 15% disclosed that they worked with suppliers to support labour practices, and only 18% engaged directly with workers in the supply chain, via site visits, worker interviews and other monitoring tools.
Lancaster University and FRC indicate that they are committed to continuing this research in coming years, and where the FRC goes, others are likely to follow. We can expect an era of more intense scrutiny. More types of reporting will be viewed through the modern slavery lens and the onus will be on business to develop a stronger narrative, explaining long term strategy and evidence-based decision making.
However, the work that organisations need to do to get to this point - tracing supply chains back to raw materials, and directly engaging with suppliers and workers at various tiers – is undeniably challenging, requiring dedication and strong direction from the board.
Thanks to my colleagues, who started Marshalls on its ethical journey in 2005 with trailblazing work in India, we have full executive backing. This year we have a busy programme of engagement, reaching out to workers and suppliers globally. Our expanded business and human rights team is scheduling site visits both at home and overseas, and we’re undergoing training on SA8000 to enable us to conduct second party audits. These will complement a range of other tools and methods that we will be detailing in later blogs. It’s a potent cocktail of activities that is undoubtedly going to be a steep learning curve, requiring a continual process of tweaking and critiquing to maximise impact.
For me, moving from the theory of modern slavery prevention work to operationalising it within a business is a surreal and rollercoaster experience. I’m finally experiencing what it’s like to bring a modern slavery statement to life.
Emma Crates is Business and Human Rights Manager for Marshalls Group plc.
I used to scrutinise modern slavery statements. Now I have to write one
