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Reporting modern slavery and human trafficking

Helpsheets and support

Published: 15 Jan 2021 Update History

Guidance on how to report if you suspect someone is a victim of modern slavery or human trafficking or if you believe it is going on in either your own firm or in a client’s business.

Victims of modern slavery or human trafficking

If you suspect that someone is a victim of modern slavery or human trafficking DO NOT approach or confront them as you may put them or even yourself in danger.

Instead contact one of the following:

Evidence or suspicions of modern slavery in your business, your supply chains or a client’s business or supply chain

If you suspect that modern slavery or human trafficking is going on in either your own firm/business or in a client’s, then you must report it but without ‘tipping off’.

If you are unsure whether the activity you have seen is modern slavery or human trafficking, then you still must report it. Often the authorities can use such reports to build up a case as they will be aware of the bigger picture

There are a number of ways to report:

  1. If you suspect it in your own firm or its supply chains report it through your firm’s usual reporting channels or whistleblowing lines. Your firm should have procedures in place for onward reporting to the National Crime Agency (NCA) via a Suspicious Activity Report (SARs). See ICAEW’s guidance for members on SARs.
  2. If you suspect it in your client then again your firm should have procedures in place to deal with such reports and for onward reporting to the NCA via a Suspicious Activity Report (see here for more details on SARs).
  3. If there is no such channels available or you feel uncomfortable reporting it internally or if you are unsure whether what you have witnessed or suspect is evidence of modern slavery or human trafficking then contact ICAEW’s helplines for further advice.

ICAEW members are reminded of their responsibilities regarding the duty to report misconduct or unlawful acts.

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