ICC United Kingdom Convene Human Rights Roundtable: Modern Slavery – A Shared Problem
By way of introduction, Andrew Wallis OBE, CEO of Unseen UK, pointed to rapid globalisation as a prominent reason behind the perpetuation of modern slavery within society: cost pressures abound and corporate supply chains are increasingly distributed, complex and difficult to police, particularly in territories with higher corruption index levels. Persistent inequalities in wealth distribution are also a factor, as impoverished or persecuted individuals are more vulnerable to exploitation. Another issue is lack of awareness, also on the part of some victims, as to what constitutes slavery. While human trafficking was long treated by authorities as an illegal immigration issue rather than a human rights breach, thinking has significantly evolved and the topic went up the political agenda: modern slavery is now rightly seen as a matter of national and international priority, in need of urgent action.
Justine Currell - Executive Director at Unseen UK and author of the UK’s Modern Slavery Act (MSA) (2015) whilst at the Home Office - explained that slavery is not just a distant, abstract issue in the UK. British nationals are just as likely to be exploited in the UK as in any other country, particularly the more vulnerable members of society. Official estimates vary dramatically, pointing to between 10,000 - 136,000 individuals enslaved in the UK, in a variety of industries ranging from fishing, manufacturing and construction, to prostitution, sexual enslavement and domestic servitude. For the past two years the UK’s Modern Slavery Helpline (run by Unseen UK) has been instrumental in shedding light on potential victims. Equipped with highly trained staff and the connections, expertise and capacity to execute on-the-ground action quickly, the team took 6,012 calls from potential victims in 2018, promptly liaising with law enforcement agencies, helplines and other NGOs to support these.
Information gathered also allows Unseen UK to work with companies to shed light on their supply chain issues and help enhance their anti-slavery controls and procedures. But progress is slow: Andrew Wallis suggested that in contrast to active enforcement by regulators of anti-money laundering and anti-corruption laws, anti-slavery regulation is not comprehensively policed throughout international and domestic supply chains. The issue needs to be given further visibility, not least because slavery has direct human, rather than purely monetary, impacts. The commodification of humans for lucrative gains must systematically be met with prompt, sustained action.
A primary area of discussion that followed was how to ensure more cohesive and effective anti-slavery programmes in business – bearing in mind that SMEs do not have the same resources as larger players. There was consensus on the need not only to promote transparency and acknowledge rather than hide challenges, but also to agree a clearer methodology for the practical application of the MSA. In a recent independent review by TISCReport.org, it was found that 4,700 out of a total of 17,000 UK companies in scope of the MSA had not met their obligations to issue a statement regarding their internal anti-slavery controls and procedures. Technically, this is a mandatory requirement, yet businesses are not sanctioned for non-compliance: it remains to be seen whether the UK government will follow through with penal consequences as outlined in its review requirements. While participants took the view that a more consistent application of the MSA is required, it was also agreed that “naming and shaming” is not necessarily the most effective approach. A proactive campaign to raise awareness among businesses would be more advisable, including attempts to incentivise compliance by appealing to collective conscience and highlighting benefits such as monetary gains stemming from maintaining high ethical and transparency standards throughout companies’ supply chains. Effective third-party compliance programmes are also needed. Other suggestions to reduce the numbers of non-compliant businesses included: making a designated board member responsible for ensuring that reporting is completed; establishing a registry to execute follow-up activities; making the independent Anti-Slavery Commissioner responsible for monitoring compliance with the law.
Lack of clarity around individual expectations also needs to be addressed. Which entities should be obliged to adhere to reporting requirements? Should a financial threshold be used to establish levels of obligation and minimum reporting requirements? And how can reporting requirements be balanced to ensure they are not so prescriptive that they result in formulaic and limited feedback, but not so open-ended that standards are not met? Such questions should be carefully considered within government when determining how best to progress the anti-slavery agenda.
In closing discussions, it was agreed more needed to be done to incentivise governments and businesses to put their weight behind the issue, particularly as the government is one of the biggest players in procurement. It was argued that the ubiquitous business model of extractive profit needed to be addressed and adapted to account for sustainability concerns. But to achieve this end, businesses must not only be shown the stick – encouragement is also required to raise awareness and trigger a cultural step change in attitude towards slavery.
UK expertise and ideas on how to move the anti-slavery agenda forward are relevant to other stakeholders: discussions need to be streamlined and output fed into government-level and international institution-level fora to accelerate the pace of progress. ICC United Kingdom is in a unique position to do just this. It acts as a platform for progress by convening a broad spectrum of stakeholders and, by virtue of its UN observer status, presence in Geneva, and operations in around 120 countries, can further the anti-slavery agenda by conveying ground-level insights such as those discussed, to policy-makers at national and international level. Inspired by its founding mission, ICC United Kingdom commits to using the full extent of its resources to tackle these 21st century challenges, while supporting private sector leaders to meet the calls of shareholders, governments and the public for a more inclusive and responsible economy.
A key objective of ICC United Kingdom’s roundtables is to lay the foundations for practical initiatives that will bestow visible benefit to its members and wider society. Indeed, this roundtable directly resulted in the formation of a Compliance Officers Network – which is to be housed within the ICC UK Corporate Responsibility and Anti-Corruption Committee. This will serve as an expert platform for focused discussions around global priorities such as human rights and sustainability. The Network will empower compliance officers to tackle these global priorities from the inside out – giving individuals the wherewithal to reassess their internal practices within their respective corporations, and adapt their business models to help further the sustainable agenda.