Consultation on transparency in supply chains

29 July 2019

Following an independent review of the Modern Slavery Act, a consultation has been published to gather views on proposed measures intended to increase transparency and compliance, improve reporting quality and extend the scope of the legislation.


Independent Review

In July 2018, the Home Secretary commissioned the Independent Review of the Modern Slavery Act. The aim of the Review, which focussed on four themes, including the transparency provisions of the Modern Slavery Act (section 54 - transparency in supply chains requirements), was to identify where the Act is working well, what can be improved in the implementation of the Act and whether specific areas of the legislation need to be strengthened.


On 22 May 2019, the final Review report was published. The transparency recommendations included clarifying the scope of organisations required to report, increasing compliance, further embedding transparency requirements into business culture, improving reporting quality and extending the requirement to publish a modern slavery statement to public sector organisations.


Geographical extent - The consultation is being carried out by the UK Government and contains proposals which relate to a mixture of reserved and devolved matters.  Separate consideration is being given to aspects of Transparency in Supply Chains policy in Northern Ireland and Scotland. Upon receipt of the consultation responses, the government will liaise with the devolved administrations as appropriate.


The consultation contains three parts. In summary, the proposals under each section are as follows:


Content of statements

  • Increase the comparability of statements to drive action and support effective external scrutiny
  • Consider making reporting on specific topics compulsory
  • Allow organisations to justify why they have not reported on one or more of the criteria
  • Consider introducing legislative changes to align the areas on which organisations are required to report in other jurisdictions


Transparency, compliance and enforcement

  • Develop an online registry for modern slavery statements published under the Act, and in parallel amend the legislation to mandate publication on this registry
  • Introduce a single reporting deadline on which all organisations must publish their statement each year
  • Consider whether the introduction of civil penalties could be an effective tool to increase compliance


Public sector supply chains

  • Extend section 54, the transparency in supply chains requirements, to public sector organisations with an annual budget exceeding £36 million
  • Ensure the proposed approach to public sector reporting mirrors the current private sector transparency requirement as closely as possible

Public bodies will be those which exercise functions of a public nature or who are providing, under contract with a public authority, any service whose provision is a function of that authority; such as those covered by the Office for National Statistics Public Sector Classification Guide or those defined as public bodies in the Freedom of Information Act. This would include, for example, Central Government Departments and their Arm’s Length Bodies (ALBs), local government bodies, including Combined Authorities, NHS bodies, police forces, and non-market and market public bodies (such as public corporations), which meet the budget threshold. Ministerial UK Government departments will be considered in the scope of the reporting requirement regardless of their annual budget.



Responding to the consultation

Government is seeking views from all parties impacted by and interested in transparency reporting, from businesses to the public sector, charities, NGOs, consumers and investors. It is looking for respondents to consider which measures will drive engagement and compliance, accelerate action and progress, and ultimately improve outcomes for vulnerable workers in supply chains both in the UK and overseas.


This consultation closes at midday on 17 September 2019.


Responses are requested via this online form.