Modern slavery: Lack of awareness and action needed

Just as the European Parliament's Legal Affairs Committee approves (non-binding) recommendations to the Commission on a draft legislative initiative on mandatory corporate human rights and environmental due diligence (by a landslide 21 to 1 vote), inching the prospect of a law that enshrines the UN Guiding Principles on Business and Human Rights that bit closer to reality, across the Channel, the UK's Independent Anti-Slavery Commissioner publishes a report showing why such a law might be necessary. 

Dame Sara Thornton's report, carried out with Themis and TRIBE Freedom Foundation, looked at the financial services sector and found that 36% of financial industry employees think their organisation has no influence in combatting modern slavery and human trafficking, with 68% believing the subject had not been raised more than "a few times" by senior management, if at all, in the last 12 months. 

While Dame Thornton has written to the CEOs of some of the major financial institutions to ask what they plan to do to address modern slavery and human trafficking within their organisation, this report highlights some big questions for the UK, namely: (i) when are the changes promised last year to the UK Modern Slavery Act reporting requirement going to be implemented; and (ii) what is the UK looking to do as regards its own rules on mandatory due diligence? 

On the latter, while the EU proposal in its current form could see third-country companies providing goods or services in the EU caught by the regime, it will be important for the UK to make a clear statement itself on what is an important topic. Critics of the Modern Slavery Act would be quick to highlight that it covers just one type of human rights abuse and falls short of requiring substantive action and that company calls for a level-playing field and legal certainty that a legislative regime would bring are only likely to get louder. 

As on climate, the financial services sector finds itself in the crosshairs. But it's not just at company level that plans and progress need to be made: Dame Thornton's report recommends leaders set the tone from the top.