Review your supply chain – slavery and human trafficking are ‘far more prevalent than previously thought’
Companies in the food & drink sector need to be aware of their obligations under the Modern Slavery Act 2015 (MSA) – do you?
The MSA came into force on 29 October 2015 and was designed to fight against slavery and human trafficking.
On 10 August 2017 the National Crime Agency (NCA) released figures that suggest that modern slavery and human trafficking is being carried out on a far greater scale than previously understood.
The NCA commented that: ‘The intelligence we are gaining is showing that there are likely to be far more victims out there, and the numbers of victims in the UK has been underestimated.’
Many areas of the food & drink industry rely on lower paid and lower skilled/qualified workers – such as seasonal fruit picking and kitchen support staff.
Unfortunately, less scrupulous employers seek to take advantage of vulnerable individuals looking for work and gainful employment. As a result, the food & drink sector is high up on the authorities’ watch list.
Under the MSA certain businesses (please see the link below) are required to review their supply chains and evidence the steps they have taken to ensure that none of their business or supply chain is tainted by modern slavery or human trafficking.
The direct scope of section 54 of the MSA tends to only cover large businesses operating towards the top of a supply chain. However, as expected, several of our small to medium sized clients that operate at different levels of a supply chain have been required by their customers to evidence the action they have taken to prevent slavery and human trafficking in their own structure – this has included anti-slavery policies and accepting anti-slavery clauses in their commercial agreements.
In short, with extra media coverage, comes additional scrutiny. The result could well be that businesses covered by section 54 of the MSA start asking members of their supply chains to confirm they too have established anti-slavery processes.
If you want to retain your customer relationships, and you haven’t done so already, now could be a good time to ensure you have (and can substantiate) good anti-slavery practices in place.