Procurement teams are under mounting pressure to comply fully with the UK Modern Slavery Act (MSA) or risk having their organisations publicly “named and shamed” in 2019. They may also face legal and litigation risks, experts have warned.
Writing for the international legal updates and analysis site Lexology, Doug Bryden and Laura Spota of the law firm Travers Smith LLP emphasised that recent months have seen increasing pressure from the UK Government, NGOs such as the Business and Human Rights Resource Centre (BHRRC) and various watchdogs to ensure that organisations comply with their corporate reporting obligations under the MSA. The latest Government guidance even encourages companies that do not meet the specified £36m “turnover threshold” to voluntarily provide an MSA statement covering the six categories detailed in s.54(5) of the act.
For procurement professionals, the pressure is undoubtedly on. In addition to their core functions, which include strategic sourcing, sourcing savings, category management and cost reduction, supply relationship management has taken on added significance under the MSA. A “tick box” approach to reporting compliance will not suffice and may result in civil proceedings, according to Kevin Hyland, the Independent Anti-Slavery Commissioner.
Issues are set to get tougher, as the Home Office announced plans in July to launch an independent review of the MSA aimed at strengthening the quest to eradicate modern slavery from the supply chains of all British companies and organisations.
Bryden and Spota advised that procurement professionals ensure regular annual updates of all MSA statements to demonstrate genuine progress and avoid charges of “box-ticking.” They also recommended nominating a designated person, possibly registered with the Home Office, in every organisation to manage the implications of the MSA on a day-to-day basis and keep abreast of regulatory updates in this area.
In addition, Bryden and Spota advised posting MSA statements prominently on company websites and voluntarily adding them to public lists provided by organisations such as Transparency in Supply Chains (TISC) and BHRRC.
Steve has over 28 years of success as CPO, MD and Procurement BPO leader in a range of industries. Steve is COO at Odesma, responsible for Odesma’s delivery capability & infrastructure.