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The importance of considering human trafficking in your supply chain

Earlier this month, the Sunday Times reported that several household retailers including Waitrose, Marks & Spencer, Sainsbury, Tesco, Asda, Argos, Travis Perkins and Wickes had been selling goods from supply chains that used workers that had been trafficked into the UK and were modern-day slaves. These organisations did not know that their supply chains had not conducted sufficient due diligence and had inadvertently forced vulnerable people to work for very little pay (usually around 50p per day), placed in unacceptable living environments and treated in an inhumane manner.

All of this information came to light in the last 6 months due to two criminal cases which concerned one large human trafficking ring which made approximately £2 million by exploiting victims. It spent 5 years controlling approximately 400 victims, many of which provided the Crown Prosecution Service with accounts of their ordeal, all of which was recorded in 250,000 pages of evidence that was presented at the trials.

The human trafficking ring infiltrated recruitment agencies so that it would have the power to place its victims into work without raising suspicious with third parties – this is one of the ways in which several household retailers became connected to the victims. When convicting the members of the human trafficking ring, Her Honourable Judge Mary Stacey referred to the human trafficking ring as the, "most ambitious, extensive and prolific modern-day slavery network every uncovered".

These two criminal cases show how sophisticated organised criminal groups have become and the importance for organisations to ensure that they comply with the Modern Slavery Act 2015, which makes it a criminal offence for an organisation to be involved in modern slavery practices.

What does your organisation need to do to comply with the Modern Slavery Act 2015?

According to section 54 of the Modern Slavery Act 2015, certain organisations are required to develop slavery and human trafficking statements which set out what they have done to ensure that modern slavery is not taking place in their business or supply chain. The steps that organisations should carry out include the following:

  • conducting a risk assessment;

  • drafting/reviewing its due diligence and auditing policies;

  • including a modern slavery assessment within supplier and sub-contractor due diligence questionnaires;

  • drafting/reviewing its standard terms and conditions with its suppliers and;

  • training staff on anti-slavery and human trafficking measures and controls.

Once all of the above has been completed, organisations can document these steps and controls in their slavery and human trafficking statements. At Aria Grace Law, our compliance team can assist you with this as well as advising you on dealing with any potential breaches of the Modern Slavery Act 2015.

What are the consequences for non-compliance with the Modern Slavery Act 2015?

If your organisation breaches the Modern Slavery Act 2015, it can face several consequences which have a long-term and lasting effect (and of course, the vulnerable individuals who are forced into slavery). Examples of the consequences include the following:

  • your organisation could face a High Court injunction forcing it to comply with the law, with the further consequence of an unlimited fine, if it does not comply with the injunction and/or;

  • your organisation could suffer reputational damage and be known to be an organisation that fails to put in place controls to prevent modern slavery and/or;

  • your organisation could lose future business such as and when responding to tenders (as it cannot assure compliance with the Modern Slavery Act 2015).

The Home Office estimated in October 2018 that 40% of organisations that are required to publish a human trafficking and slavery statement have failed to do so and from the 60% of organisations that have done so, the quality of some of their statements is poor and fails to meet the basic legal requirements. The Home Office conducted an independent assessment of the Modern Slavery Act 2015 in May 2019 and reported that it intends on putting teeth into section 54 so that organisations take their responsibilities seriously to audit their supply chains.

In light of this and the significant number of victims that have and are continuing to suffer at the hands of human trafficking rings, it is now more important than ever that organisations put in place anti-slavery and human trafficking programs to ensure compliance with section 54 of the Modern Slavery Act.

About Aria Grace Law: We are commercial lawyers as well as being specialists in several areas of advising corporate clients on compliance including anti-slavery and anti-human trafficking. If you have any questions or need advice in this area, please contact our anti-slavery and anti-human trafficking experts on

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