It’s a little over a month since the UK Modern Slavery Act came into force, following in the footsteps of its precursor, The California Transparency in Supply Chains Act. All organisations that do business in the UK and have a global annual turnover of £36 million are now required to publish a slavery and human trafficking statement on their website with a link to the statement in a prominent place on the homepage. So how should businesses go about reporting their approach to human trafficking and slavery?
Cold compliance vs genuine commitments
One approach would be to lock a crowd of company lawyers in a room and publish the ensuing legalistic treaty on the website – job done, right? In a way – yes; but this is a missed opportunity. Slavery and human trafficking are hugely emotive crimes. People want to see that companies share their abhorrence for them. Whilst an ice-cold technical statement shows that a company follows the law, it doesn’t show people that the company feels the issue – it doesn’t show people that the company actually cares, and the commitments it has made to do things differently.
A better approach is to produce an accessible and engaging statement that shows interested consumers that the company shares their disgust at modern slavery and is committed to ensuring that it is always absent from their supply chains. Businesses can show consumers that they do this not simply because the government is telling them to, but because they believe it is the right way to do business. This offers reassurance to consumers and investors that they are not associating with a cold, dusty, corporate machine. There is a soul in the machine.
A different type of teeth
But what happens if companies don’t comply with the new regulations? Whilst the act does technically have “teeth” – the Home Secretary can bring High Court proceedings if companies fail to comply – the main driver of compliance will be through the court of public opinion. Consumers and investors have a new source of information to use when deciding if they want to be associated with a company. As stated in a recent Home Office Consultation Summary, the Act “will allow investors, consumers and the general public to decide who they should and should not do business with.” Modern slavery is a live issue and public awareness is on the rise – in 2014 the Home Office ran a £2.18m marketing campaign to raise awareness which reached 93% of all UK adults. Watch out for the first NGO that ranks companies according to disclosure on this topic.
Over the coming year it will be interesting to see how different companies approach their human trafficking and slavery reporting. We’ve already had a number of clients at Corporate Citizenship asking about this issue and planning for it in their reporting. For me, showing genuine empathy for those affected by human slavery and for the public’s concerns by committing to the right actions and processes to effectively manage the issues, is the best approach.