• GL
Choose your location?
  • Global Global
  • Australia
  • France
  • Germany
  • Ireland
  • Italy
  • Poland
  • Qatar
  • Spain
  • UAE
  • UK

Modern slavery reporting guidance during the coronavirus COVID-19 pandemic

29 April 2020
Business women
In light of the rapid spread of COVID-19 and subsequent impact on businesses' supply chains, the Government has issued new guidance advising businesses that they will need to consider how changes to their operating model and fluctuations in demand during the pandemic may lead to new or increased risks of human trafficking or labour exploitation. This article looks at the Government's advice in more detail.

The Home Office has issued guidance to those businesses required under section 54 of the Modern Slavery Act 2015 to publish an annual modern slavery statement on how these businesses should approach the issue of modern slavery in their operations and supply chains during the COVID-19 pandemic. The guidance reminds businesses that they should continue to address the risk of labour exploitation as normal, while also considering how changes in supply and demand may pose increased risks, both within their internal operations and through the supply chain.

Permitted delay in publishing modern slavery statement

The government has stressed that the COVID-19 pandemic will not be seen as an excuse for businesses to ignore their modern slavery compliance obligations. Equally, the Home Office acknowledges that many businesses will be facing new and unique challenges during this period which may affect their ability to publish a modern slavery statement within the usual timeframes, due to reduced staff capacity for example. The normal timeframe to publish a statement is as soon as possible after, and in any event within six months of, the end of their financial year, but in the current climate businesses are permitted to delay publication of the statement by up to six months. However, businesses who choose to avail of this extension will need to provide a reason for the delay and report on action taken during this period in their statement.

Addressing modern slavery risks during the COVID-19 pandemic

Businesses should also consider the following areas which may be more vulnerable to modern slavery abuses while the pandemic is ongoing:

Health and safety

Ensure that relevant local or national governmental COVID-19 policies are implemented throughout the supply chain. This may include putting in place social distancing measures, closing premises, or paying statutory sick pay.

Engage with and support suppliers

Avoid late cancellation of orders and pay for goods or services previously requested wherever possible. Aside from causing potential contractual disputes, failure to pay for orders can put pressure on suppliers which may lead to workers not being paid or being forced to work longer hours.

Modern slavery policies

Employees and workers must still be able to access relevant modern slavery or grievance policies and procedures (for example while on furlough or working remotely). Businesses should also ensure that processes are in place to enable workers to lodge a grievance during the pandemic, should it become necessary to do so.

Recruitment

Recruitment (in particular the use of outsourced recruitment agencies) should always be considered as a risk area for human trafficking and labour abuses. During the pandemic this risk may be higher due to an increase in demand for short term, low-skilled labour. Businesses should ensure that they are maintaining stringent checks during the recruitment process, and implement the same measures through supply chains.

The above is not an exhaustive list. Businesses should regularly review the situation and undertake risk assessments as appropriate.
If you have any questions regarding modern slavery compliance and COVID-19 or need any support, please do not hesitate to get in touch the contact details shown below. For more insights relating to COVID-19, please see the DWF COVID-19 Legal Insights Hub.

Further Reading

We use cookies to give you the best user experience on our website. Please let us know if you accept our use of cookies.

Manage cookies

Your Privacy

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. We mainly use this information to ensure the site works as you expect it to, and to learn how we can improve the experience in the future. The information does not usually directly identify you, but it can give you a more personalised web experience.
Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change permissions. However, blocking some types of cookies may prevent certain site functionality from working as expected

Functional cookies

(Required)

These cookies let you use the website and are required for the website to function as expected.

These cookies are required

Tracking cookies

Anonymous cookies that help us understand the performance of our website and how we can improve the website experience for our users. Some of these may be set by third parties we trust, such as Google Analytics.

They may also be used to personalise your experience on our website by remembering your preferences and settings.

Marketing cookies

These cookies are used to improve and personalise your experience with our brands. We may use these cookies to show adverts for our products, or measure the performance of our adverts.