Blog - Strategy

How Does Your Board approach the Modern Slavery Act?

Posted by Scott Newton on Sep 1, 2022 8:32:09 PM

Slavery in 2022? Are you joking?

Slavery remains a major issue in business, and there are an estimated 21 million people worldwide that are victims of forced labour. 44% of victims of slavery are transported across international borders against their will.

 Governments and policy makers are beginning to address the issue of Slavery, and the UK Modern Slavery act is one of the most far reaching pieces of legislation worldwide.

The UK Modern Slavery Act states that companies must publish an annual statement if they have annual sales of more than £36 million and if some or all of their business is in the UK.

The statement by each company must confirm and detail the steps taken to ensure slavery and human trafficking are absent from the business and supply chain. If the company is unable to confirm this statement, alternatively the organization must declare that no steps have been taken to prevent slavery.

A round table this year of non executive directors including the barrister Hon. Lady Cherie Blair in London revealed that only 1 in 3 statements were clear and easy to read, and that at least 10% of organizations required to report still had no apparent modern slavery statement at all.

Whether your organization operates in the UK or not, ensuring your business has a clear policy regarding forced labour and slavery is a must in 2022.


Most organizations have a clear idea of how their first level suppliers operate, yet moving to second, third, and raw material providers for example this picture becomes much more murky and difficult to follow.

Some firms have been tempted to move this to a compliance issue or outsource the reporting. The reality is this is a Strategic Governance issue that must be actively monitored by the Chair, the board, the CEO, and a key agenda item for your Audit and Risk committees. 

With your employees, investors, customers, and stakeholders, there is one key question that everyone is asking: "Do you stand by your values?"

This is a test of both reputation and integrity.

The round table with NED ON BOARD lead to some practical guidance and questions you can use in setting this Clarity, and ensuring the guiding values for your firm are aligned with your Strategy:

1. Think in a Systematic and Clear Way about Risk Assessment.

2. Ask the question and challenge yourself and your suppliers "What are good business practices?"

3. Build this as part of the culture of your board. What are the leading indicators we are eliminating slavery from our business practices and models? What reliable data tells us we are succeeding?

4. Look for evidence and not just data. What is your one page version regarding ethical data. Ask throughout your organization "What are we talking about?" and listen actively for surprising answers.

5. How do the decisions you are taking strategically support your stated beliefs and values? How is DD and compliance embedded in to your Strategy and Execution system(s)?

Businesses are not neutral actors, and your influence and decisions will impact the lives of millions around the world. 

What decisions will your board and leadership take today to ensure you are ready for the future?