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UK Annual Report on Modern Slavery

In the third of our series of three articles, we explore the Government’s ‘4 Ps strategy’, utilised to tackle modern slavery nationwide, and its implications for businesses.

The current strategy

The Government is utilising the four ‘P’s structure favoured by the Home Office to tackle terrorism and serious and organised crime: Pursue, Prevent, Protect, Prepare.

For businesses operating in the UK, the ‘Protect‘ strand is the most relevant.

The Government emphasises the key role of businesses in tackling modern slavery. This is no surprise given that data reveals that the biggest exploitation sector was labour exploitation, accounting for 1,578 potential victims.

What do businesses need to do?

The Modern Slavery Act requires large businesses to publish an annual statement setting out the steps they have taken to ensure that there is no modern slavery in their business and supply chains. The guidance on these requirements has recently been strengthened by the Government. Please see our briefing here.

A report by the Business & Human Rights Resource Centre[1] found that 43 of the top 100 FTSE companies are not currently meeting the minimum requirements of the Act. The Government is alive to this issue and businesses should be aware that greater scrutiny is therefore being placed on compliance. The BRRC has a central registry of the UK’s modern slavery statements[2] which have been ranked in terms of their compliance and quality. This could be used by businesses as a starting point, in conjunction with the Government’s guidance.

How can businesses identify modern slavery risk?

The following are the top five countries of origin for potential adult victims of modern slavery[3]: Albania, Vietnam, UK, Nigeria and China. This data can be used by businesses to identify more easily those at highest risk in their businesses and supply chains.

The typology of modern slavery developed under the ‘Prevent’ strand of the Government’s strategy can assist businesses in identifying potential victims[4]. Labour sector victims either work:

  • for multiple purposes in isolated environments (e.g. farms)
  • directly for offenders in businesses or sites that they own or control
  • work for non-offenders in a legitimate low-skilled job, with legal working conditions but offenders take away all or most of their wages (often through control of the victims’ bank accounts)

It was found that in the labour sector victims of modern slavery were usually male, and were often recruited into construction, cleaning, factory work, agricultural work, restaurants, nail bars and car washes. However, businesses should be aware that modern slavery can arise at almost any point in a supply chain, and will not necessarily be confined to the labour sector. For example, mining operations often result in large influxes of workers and this can create a demand for commercial sex[5].

The strategy and business[6]

  • The Home Secretary has launched a new ‘Business Against Slavery’ forum. This group brings together a group of committed CEOs from leading businesses to help identify how best to drive up standards and accelerate progress in tackling modern slavery in supply chains.
  • Transparency in business and supply chains will continue to be emphasised.
  • There is a drive towards increased prosecutions for modern slavery offences.
  • The UK Government will stay committed to working with business, NGOs and other countries to eradicate modern slavery in global supply chains.

Our advice

With an increased awareness of the problems around modern slavery it appears that the only likely movement in this area will be increased legislation and increased prosecutions. To the extent the MSA may have had a quiet introduction, it is clear there is legislative and political pressure to ensure businesses comply with their obligations, and hence we would advise all those affected to ensure they are both compliant and have an awareness of their responsibilities. Failure to do so could well see action taken.

UK Annual Report on Modern Slavery

A link to the full report and detail behind the ‘4 Ps’ can be found on the government’s website, here.

For more information or guidance, please contact:

Stephen Blair
Partner, Head of Corporate and Corporate Restructuring
T. 020 7227 7254

Sejal Raja
Partner and Head of Employment
T. 020 7227 7410

Angharad Birch
Trainee Solicitor
T. 020 7227 7270

[1] Business & Human Rights Resource Centre, FTSE 100 At the Starting Line: An Analysis of Company Statements Under the UK Modern Slavery Act, October 2017, <>, [accessed, 30 October 2017]
[2] [accessed 30 October 2017]
[3] Home Office, 2017 UK Annual Report on Modern Slavery, October 2017, page 10
[4] Home Office, A typology of modern slavery offences in the UK, Home Office Research Report 93, 17 October 2017
[5] The London Economic, FTS100 companies need to do more to protect women and girls from sex trafficking, 18 October 2017, <>, [accessed 30 October 2017]
[6] Home Office, 2017 UK Annual Report on Modern Slavery, October 2017, pages 49 – 51

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