The Modern Slavery Act 2015 has been with us for a little over two years, and larger companies are now well used to preparing the transparency statements the Act requires.  As this article illustrates, however, the complexity of modern supply chains and the disturbing prevalence of trafficking in some industries and territories makes this an ongoing compliance issue for many sectors.

Campaigners might also point to the Act's lack of an effective sanction as a fundamental obstacle to progress.  The Act allows the Government to ask the courts to order a company to make the necessary statement, but includes no meaningful financial sanctions for non-compliance.  What is more, the legislation does not impose any formal requirements for the statement itself - a company could comply simply by saying that it has taken no steps to deal with slavery in its supply chain.  

The Government's intention, of course, was that shareholder and media pressure would provide a more effective incentive to meaningful compliance, and for many organisations that is undoubtedly true.  The difficulty of tackling the issue on a multilateral basis, and the lack of an effective sanction in the UK legislation do, however, make one sceptical over the prospects for a material improvement in the short- to medium-term.