An 'Unseen' way to tackle transparency in the supply chain

Justine Currell, executive director of Unseen, draws on her experiences to shed light on new tactics to improve transparency in the supply chain and counter modern slavery.

Although the transparency in supply chains provision in the Modern Slavery Act 2015 only came into full effect from 31 March 2016, it has already made a significant impact across all business sectors both here in the UK and globally.

Section 54 of the act requires any commercial organisation carrying on a business or part of a business in the UK, providing goods or services, and with a total annual turnover of £36m or more to publish an annual slavery statement. The statement must set out the steps the business has taken to ensure there is no slavery in their supply chains or their own organisation.

Given the breadth of the legislation it is likely that many businesses who may have not thought about such issues are now grappling with how they should respond to this new requirement. Tackling modern slavery needs to be seen as a journey. It is not about confirming that there is no slavery in your supply chain or organisation from the outset, it’s about recognising where and how slavery can happen and the proportionate steps needed to defend against it. The truth is, slavery can infiltrate any sector, organisation or supply chain if the appropriate due diligence is not applied regularly and risks not assessed or mitigated. 

Businesses need to be pragmatic, realistic and proportionate about the steps they can take. Sector-wide collaboration is vital to share good practice and concerns and to tackle what are often recognised as common or shared risks. Requiring businesses to make an annual statement about their actions is a real positive step forward and genuinely provides a platform for increased transparency - but the statement is simply a means to an end. 

The policies, practices and procedures underpinning a statement made by an organisation are what’s important. Recognising that this is not a fight that can be won overnight, or by putting out a yearly statement, is a key message in developing effective strategies and practices for the longer term. For the first time, boardrooms across the UK and beyond are required to approve and sign a statement on the steps they have taken to tackle modern slavery. That puts the issue of modern slavery firmly at the centre of boardroom discussions. 

With the new requirement, many are expecting businesses to fail to take action, do the legal minimum, or simply pay lip service to the legislation. In reality, the legal minimum is all the steps a business has taken in that year, positive or negative. Our collective challenge is to ensure that the business community drives forward the charge on modern slavery and is in a position to set the agenda, using the legislation as a springboard. Introducing further more prescriptive legislation, or benchmarking and ranking businesses from across disparate sectors, at this point in time is simply counterintuitive.

That is why the central registry at www.tiscreport.org is so important and unique. It allows businesses to be totally transparent about what they are doing in a neutral and supportive environment by encouraging businesses to engage openly and proactively with the issue. 

Tiscreport is a central registry for business, backed by business. Supported by the International Chamber of Commerce, the Chartered Institute for Procurement and Supply, Business West Initiative and the Welsh Government, tiscreport provides tools, guidance and support to businesses wanting to do the right thing. It is also the only central registry that does not rank, tier or benchmark businesses. It works to increase collaboration, recognising that up-front engagement directly with business is the key to driving positive behavioural change.  

For more information about transparency in supply chains or tackling modern slavery visit www.tiscreport.org or call Unseen on 01767 686800.

Justin Currell is executive director at Unseen, an organisation that looks to increase transparency in the supply chain and foster a world without slavery. Previously Currell served as a senior government policy advisor for the Modern Slavery Act and transparency in the supply chain.