4 April 2025
At CCLA, we dedicate significant effort to engaging with individual companies to enhance their approach to addressing modern slavery. To support this work, we also engage with UK policymakers aimed at pushing for more progressive modern slavery legislation.
One such example is our engagement with the Home Office Forced Labour Forum, a group of stakeholders from business, civil society, academia and trade unions. Through this Forum, we have been heavily involved in a series of meetings over several months with the Home Office and their consultants during the drafting stage of updated statutory guidance for the 2015 Modern Slavery Act’s Transparency in Supply Chains provisions.
The provisions are set out in section 54 of the Act and require businesses operating in the UK above a certain size to report annually on the steps they have taken to tackle modern slavery in their operations and global supply chains. The corresponding guidance provides advice on how organisations can produce high quality modern slavery statements and develop a more effective approach to tackling modern slavery.
In meetings with the Home Office, we showcased the CCLA UK Modern Slavery Benchmark and emphasised our view that businesses should be encouraged to find, and to report on, instances of modern slavery in supply chains. Modern slavery is likely to exist in the supply chain of almost every company. Therefore, rather than indicating an absence of modern slavery, we believe that failing to ‘find it’ demonstrates that a company’s human rights due diligence processes are inadequate.
In March, coinciding with the ten-year anniversary of the Modern Slavery Act, the Home Office published its updated statutory guidance.1 We were very pleased to see that the new guidance draws on CCLA’s UK Modern Slavery Benchmark framework and that our benchmark is linked to and positively referenced in the guidance. The statutory guidance states:
A useful resource to support organisations developing KPIs in the above areas is the CCLA Modern Slavery Benchmark. The CCLA Benchmark includes several metrics under each of the above areas, and organisations could use these to develop suitable KPIs for their business.2
We expect that the guidance will be the first port of call for all companies in scope of and working to comply with the Modern Slavery Act and are delighted that our benchmark has received such acclaim.
The political backdrop
The Labour government has set out its intention to take a “tougher stance against businesses that do not meet our expectations in tackling forced labour” (Minister for Safeguarding, Jess Phillips)3. It has also committed to publishing a new modern slavery action plan, which will include a focus on prevention, as well as remedy. We were delighted to see Phillips’ adoption of our view that,
Modern slavery is so prevalent that if businesses are not identifying risks and cases, they are probably not looking hard enough.4
Whilst momentum is building at home on strengthening the Modern Slavery Act, there is also growing pressure on the UK to get this work done, following the development of mandatory human rights due diligence legislation by European peers.5 We will continue to do our bit to ensure that this work comes to fruition.