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Modern slavery statements: good and bad practice

The UK’s Modern Slavery Act 2015 (MSA) is widely regarded as a pioneering piece of legislation which not only sought to help victims but for the first time recognised that business had a role to play in preventing modern slavery.

As a result, some commercial organisations now have a legal obligation to publish annually a Modern Slavery Statement specifying what they are doing to find and prevent modern slavery in their business and supply chains.

In this guide we highlight some of the common errors and omissions found in a cross section of Modern Slavery Statements. It is not a definitive guide and it is not legal advice. If in doubt members are advised to seek specialist and independent legal advice.

What should a Modern Slavery Statement include?

The MSA does not dictate the form and content of a Modern Slavery Statement, although there are some procedures that must be followed to ensure compliance. The government, however, has recommended a number of topics and details to include as best practice.

Many statements, however, are woefully short on detail. In the light of this the government announced in September 2020 that it will consider whether to mandate what should be included but only when parliamentary time allows.

Who should read this guide?

This guide is for anyone preparing or reviewing a modern slavery statement. It highlights the common omissions and suggests some examples of best practice that members may wish to adopt.

How to use this guide

The guide is divided into three sections:

  • Mandatory Procedures – this section considers the procedures that must be followed to ensure compliance with the MSA.
  • Completeness – this section covers the information that should be provided and the level of detail needed to understand an organisation’s exposure to the risk of modern slavery and human trafficking occurring within its business and supply chains.
  • Best Practice - this section reviews how organisations have included (or not) the six areas that the government currently suggests may be included in a statement as best practice.

Further information

ICAEW’s Modern Slavery Hub [insert link] aims to help members, whether in business or practice, to navigate the risks of modern slavery reporting. It includes guides and webinars on the legal requirements in the UK and elsewhere, how to prepare a Modern Slavery Statement, how to spot modern slavery and what to do if you do. There is sector specific guidance and general guidance. More is planned but if you can suggest other ways we can help or can offer some tips based on your own experience or that of your clients please contact us at bam@icaew.com.
Download our exclusive guide to good and bad practice when writing a Modern Slavery Statement

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Read this ICAEW know-how guide highlighting best practice and revealing some common errors and omissions.