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Major international companies in the agricultural, clothing and extractive industries have recently been assessed in respect of human rights standards in their businesses and supply chains. The 2018 Key Findings Report issued by the Corporate Human Rights Benchmark (CHRB) was released on 12 November 2018. The report scored 101 of the largest publicly traded companies in the world on a set of human rights indicators built on the UN Guiding Principles on Business and Human…
In November 2018, the Business and Human Rights Resource Centre released its third annual assessment of FTSE 100 companies’ modern slavery disclosure under the UK Modern Slavery Act 2015 (the MSA). The MSA, requires companies with a turnover of not less than £36 million to produce an annual statement outlining the steps they have taken to tackle forced labour and human trafficking in their operations and supply chains. FTSE 100 companies are the largest in…
Earlier this year, the Financial Action Task Force (FATF) together with the Asia Pacific Group on Money Laundering (APG) published a report analysing the financial flows associated with human trafficking. The report: summarises indicators of financial transactions that are laundering the proceeds of human trafficking (e.g. multiple wages being paid into one account, rapid in/out transactions following receipt of wages); identifies challenges and good practices in detecting, investigating and prosecuting money laundering from human trafficking;…
Earlier this year, the European Commission published a recommendation in relation to the non-binding guidelines for the identification of conflict-affected and high risk areas and other supply chain risks under the new Conflict Minerals Regulation.[1] The Conflict Minerals Regulation, which will apply from 1 January 2021, lays down supply chain due diligence obligations for importers of tin, tantalum and tungsten and their ores, and gold originating from conflict-affected and high risk areas, frequently referred…
Earlier this year, the Home Office announced its plan to launch an independent review of the Modern Slavery Act 2015. Led by Frank Field MP, Baroness Butler-Sloss and Maria Miller MP, the independent review aims to strengthen the UK’s ongoing response and accelerate progress from the government and businesses in eradicating modern slavery. This review coincides with a new report published by the Home Office which estimates the cost of modern slavery as up to…
The UK Bribery Act 2010 (the Act) is currently undergoing post-legislative scrutiny, the process for which was set out by the Government in 2008. In June 2018, the Ministry of Justice published a memorandum which scrutinises the Act almost seven years after it was first enacted. The memorandum provides a useful insight into the scope, implementation and enforcement of the Act. Key takeaways Raising awareness: The Ministry of Justice has concluded that the corporate offence…
Earlier this year, Camilla de Silva, the Joint Head of Bribery and Corruption of the Serious Fraud Office (SFO) gave a speech on: the future of corporate criminal liability; the SFO’s considerations when entering into a DPA; use of AI to assist with disclosure; and how the SFO will deal with privileged material going forward. Corporate criminal liability Ms de Silva highlighted that the current law on corporate criminal liability, which relies primarily on the…
2017 marks the first year when all companies covered by the UK Modern Slavery Act 2015 must publish a statement. Under section 54 of the Act – which is similar to the California Transparency in Supply Chains Act – commercial organizations that do business in the UK and have a global turnover of at least £36 million in any financial year are required to publish a slavery and human trafficking statement. The statement must state the steps they…