UK businesses still have to report on the actions taken to address modern slavery during the Coronavirus pandemic, but can delay publication of their statements for up to 6 months where necessary: Home Office Guidance (20 April). The reason for the delay must be stated in the eventual report.
Fluctuations in demand and changes in operating models may cause new or increased risks of labour exploitation, and work to address these new/increased risks may take precedence over earlier goals; the next statement should show how risks were monitored during the pandemic and how the business adapted in response.
The guidance flags the need for businesses to:
· ensure relevant local/national government policies on health & safety (eg social distancing, sick pay) are implemented throughout their supply chain;
· prioritise engagement with suppliers, including paying for orders already in production (late cancellation of orders that are no longer needed may mean workers are not paid for work done);
· ensure workers can still access grievance procedures (and that these are adapted where necessary);
· maintain rigorous checks during recruitment of additional workers to meet increased demand, to ensure vulnerable workers are not exploited anywhere in the supply chain;
· consider new risk assessments and reconsider the prioritisation of previously identified risks
As well as focusing on the health and safety of their workers, businesses will need to consider how fluctuations in demand and changes in their operating model may lead to new or increased risks of labour exploitation.