We invited Ben Cooley, CEO of Hope for Justice, Rob Elvin managing partner, Squire Patton Boggs (Manchester office) and Susan Banister from the Slave-Free Alliance to join us with senior HR representatives from Greater Manchester's largest organisations and guests to explore the state of Modern Slavery & Trafficking today and the actions we can take to end these crimes.
Read our blog series
Modern Slavery & Trafficking Forum | Manchester 26 June 2019
Modern Slavery &
CIPD Manchester Branch
26 June 2019
1805 - The legal perspective on Modern Slavery
Rob Elvin, Squire Patton Boggs
1820 - What can we do to overcome Modern Slavery and Trafficking
Ben Cooley, Hope for Justice
1845 - What practical actions can organisations take (part 1)
Susan Banister, Slave Free Alliance
1855 Table discussions - identifying risks
1910 - What practical actions can organisations take (part 2)
Susan Banister, Slave Free Alliance
1925 - Panel/Q&A - Rob Elvin, Ben Cooley, Susan Banister
1955 - Closing comments
Confidentiality / Social Media
• It is fine to quote what the main speakers say
• For all other discussions, we’ll use the Chatham House Rule so we…
'are free to use the information received, but neither the identity nor the
affiliation of the speaker… may be revealed’
• Where something is totally confidential and not to go outside of the
room, please be clear on that
Modern Slavery: The Legal Case
§ Estimated 40.3 million people are in modern slavery, with 13,000 in the UK (Global Estimates of Modern Slavery:
Forced Labour and Forced Marriage , Geneva, September 2017.).
§ 71% of the 40.3 million people in modern slavery are women or girls.
§ Modern slavery is the second largest criminal industry in the world (United Nations).
§ Organisations may have modern day slavery taking place within their supply chain around the world,
and might not even be aware of it.
§ Necessary to update the definition of slavery to fit the 21st century.
Modern Slavery – the legal definition
§ Three criminal offences to constitute modern day slavery under MSA 2015:
§ Slavery or servitude – (the status of or condition of a person over whom any or all of the powers
attaching to the right of ownership are exercised)
§ Forced or compulsory labour – (any type of labour that is forced upon or compulsory for someone,
and the victim need not be aware they are in forced or compulsory labour).
§ Human trafficking and committing an offence with intent to commit human trafficking - (the
arranging or facilitating of the victim’s travel, with or without their consent, with a view to their being
• Exploitation can include (but is not limited to):
- Servitude and forced or compulsory labour;
- Indecent photography of children;
- Sexual offences
- Subjecting a victim to force, threats or deception to induce them to provide services of any kind, provide
another person with benefits of any kind, or to enable another person to acquire benefits of any kind
Obligations on organisations imposed by the MSA 2015
§ Must produce a slavery and human trafficking statement each financial year.
§ Statement must set out the steps taken to ensure that the business and supply chain is free of slavery
and human trafficking (or confirm that such steps have been taken).
§ Statement must be published on website with a prominent link or, if there is no website, available upon
request within 30 days.
§ Statements must be published as soon as reasonably practicable after the end of each financial year
and, in all cases, within 6 months.
What information must be included in the statement?
§ The Act does not set out precisely what form the statement must take, but
sets out six suggestions as to what information it may include:
§ organisational structure of the business and its supply chains;
§ policies in relation to slavery and human trafficking;
§ due diligence processes in relation to slavery and human trafficking in the
business and supply chains;
§ identified areas of risk of slavery and human trafficking within the organisation, and
the taken to assess and manage that risk;
§ effectiveness in ensuring that slavery and human trafficking is not taking place in
its business or supply chains, measured against appropriate performance
§ the training about the issue available to its staff.
Who do the provisions apply to?
§ Any commercial organisation;
§ Carrying out a business or part of a business in the UK which supplies goods or services; and
§ With a total annual turnover (including that of any subsidiary companies) of not less than £36m.
Why should you comply?
§ An important issue – morally right to do so.
§ Although no financial or criminal sanctions, failure to comply could lead to an injunction being granted
against a non-compliant organisation in the High Court.
§ Reputational damage of not complying, e.g. threat to brand value, company reputation and investor
§ Potential to discourage modern day slavery activity within your supply chain if seen to be acting against
Regional desks and strategic alliances
West Palm Beach
United Nations 2030 Agenda for
Sustainable Development Goals: Modern
5.2 Eliminate all forms of violence against all women and girls in the public and private spheres,
including trafficking and sexual and other types of exploitation
8.7 Take immediate and effective measures to eradicate forced labour, end modern slavery and human
trafficking and secure the prohibition and elimination of the worst forms of child labour, including
recruitment and use of child soldiers, and by 2025 end child labour in all its forms
16.2 End abuse, exploitation, trafficking and all forms of violence against and torture of children
Modern Slavery Act 2015
In 2015, the UK government introduced legislation that requires all businesses operating in the UK with a turnover greater
than £36m to publish an annual statement detailing activities performed in the past year to eradicate modern slavery within
their organisation and supply chain.
• Consolidated and simplified existing offences into a single act
• Ensures perpetrators can receive suitably severe punishments for these appalling crimes – including life sentences
• Created role of Independent Anti-Slavery Commissioner to improve and better coordinate the response to modern
What practical actions can
organisations take? Part 1
• Ensure all UK workers receive minimum wage and have robust immigration checks.
• Map supply chains to identify where there is highest risk and exposure to modern slavery
• Undertake site inspections
• Provide training to employees and local suppliers on modern slavery risks and compliance
• Review supplier contracts to include obligations to comply with MSA 2015
Ethical Hiring and Recruiting
• Experience has shown that recruitment stage is often where workers are most at risk
from modern slavery exploitation, especially where third party labour recruiters are
• Only work with formal labour providers who are legitimate, registered business entities
• Have clear Service Level Agreements in place with your labour provider
• Conducting checks on the labour providers’ management systems, including agency
• Have regular conversations with agency workers to understand if they have been
Ethical Recruitment and Hiring
• Recruitment stage is often where workers are most at risk of
modern slavery exploitation especially where third party
labour providers are involved.
• Only work with formal labour providers who are legitimate,
registered business entities
• Have clear Service Level Agreements in place with your
• Conduct checks on their management systems including
• Have regular conversations with the agency workers to
understand if they have been treated correctly
What practical actions can
organisations take? Part 2
“AstraZeneca is very pleased to be the first life sciences member of Slave-Free Alliance. We
chose you for the hands-on experience in working with victims globally, for actively
engaging with companies to assess their risk management frameworks and to advise on
We see a great gain for our business to tap into the first hand, true global experience and
knowledge that Slave-Free Alliance has as part of the bigger Hope for Justice umbrella.
We’re looking forward to a great partnership and a very active dialogue.”
Jim Massey, VP Sustainability Strategy and Engagement
What do others say?