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Guidance for complying with US and EU forced labour legislation:
  • US - see here
  • EU - The EU Commission and the European External Action Service have published guidance on due diligence to help EU companies address the risk of forced labour in their operations and supply chains, in line with international standards. It also aims to help EU businesses take the appropriate measures on due diligence ahead of the Corporate Sustainability Due Diligence Directive (CSDDD) coming into force. There has not yet been any specific guidance produced on the CSDDD and the regulation to prohibit products made using forced labour as they are currently progressing through the EU legislative process. However, DBT colleagues in Brussels will continue to monitor this and will let them know if they hear of any anticipated guidance. 
Home Office update on group level reporting in Section 54 of the Modern Slavery Act:  
  • Group level reporting requirements are outlined in section 3 of the statutory transparency in supply chain guidance on GOV.UK: Transparency in supply chains: a practical guide
  • Companies which are required to comply are outlined in section 3.1 of this guidance:
            1 Any organisation in any part of a group structure will be required to comply with the provision and produce a statement if they: 
      • are a body corporate or a partnership (described as an “organisation” in this document), wherever incorporated
      • carry on a business, or part of a business, in the UK
      • supply goods or services
      • have an annual turnover of £36m or more
  • Further details and example of group structures with a subsidiary abroad can be found in Annex C of the statutory guidance here Transparency in supply chains: a practical guide
  • In the Home Office’s response to the transparency in supply chain public consultation in September 2020, it was outlined that group level reporting will still be accepted, however they will require grouped statements to name entities covered. These extra reporting measures will be clarified through additional primary legislation alongside other measures to enhance the UK’s transparency approach. 
  • The Home Office welcomes any further feedback through this group on specific points which are unclear and/or the difficulties experienced in practise so guidance can be improved.
     
Information on forced labour risks and where these are on the FCDO website/country factsheets for businesses: 
  • Overseas Business Risk Guidance is publicly available information produced by staff at Post detailing the risks of doing business in overseas markets. The development and publication of the information is joint owned by the Foreign Commonwealth and Development Office and the Department for Business and Trade and includes information on political issues and human rights risks. It is not mandatory for the guidance to cover forced labour, though some pages do currently reference it. We continue to review ways to improve on this and welcome your views.