New Report Finds Modern Slavery Reporting Laws and Practices Don’t Go Far Enough to Protect Workers


March 27, 2019


Tony Franquiz, (202) 374-5393,


Emily Kenway, (+44) 7931 687 890,


New Report Finds Modern Slavery Reporting Laws and Practices Don’t Go Far Enough to Protect Workers

The report, by ICAR and FLEX, calls on companies and governments to do more to prevent forced labor and human trafficking in global supply chains


WASHINGTON – A new report by the International Corporate Accountability Roundtable (ICAR) and Focus on Labour Exploitation (FLEX) finds that modern slavery reporting requirements around the world currently fail to adequately prevent forced labor and human trafficking in global supply chains. The report, Full Disclosure: Toward Better Modern Slavery Reporting,” recommends actions for governments to improve modern slavery laws and consider alternative regulatory options, and for companies to improve reporting practices in order to identify, address, and prevent instances of modern slavery.

“Forced labor and human trafficking are some of the most egregious human rights violations found in today’s complex global supply chains. The improvements to modern slavery laws and reporting practices identified in our new report are necessary steps to better protect human rights and reduce unfair labor practices around the world,” said ICAR Interim Executive Director Meg Roggensack. “As the UK MSA Independent Review concludes and several other jurisdictions around the world are considering supply chains legislation, our report provides key and timely recommendations to governments and companies alike.”

The report’s findings and recommendations are drawn from 28 interviews and two in-person expert consultations conducted by ICAR and FLEX in London and Washington, D.C., which provided input from 15 companies, 38 civil society organizations and trade unions, 12 governments, and four investor groups. The report assesses the effectiveness of current modern slavery reporting laws around the world, including California’s 2010 Transparency in Supply Chains Act, the UK Modern Slavery Act of 2015, and Australia’s Modern Slavery Act of 2018. It makes recommendations to improve modern slavery laws, and recommends ultimately moving toward mandatory human rights due diligence legislation to generate more meaningful improvements for right-holders. It also outlines better practices for company human rights disclosures.

“The first wave of modern slavery reporting has now been reviewed and analysed by experts. Whilst reporting has served a purpose in highlighting the long road ahead in achieving improvements for workers in supply chains, it is now time for businesses to face up to the risks of abuse and exploitation posed to workers in their supply chains,” said Caroline Robinson, FLEX Chief Executive. “This report sets out a roadmap to achieving risk-based reporting, in which companies undertake detailed review of the impact of their operating behaviours and environment on workers. Key to the success of this work is meaningful engagement with workers on the ground, in order to shine a light on abuses and seek urgent remedies.”

The report’s key findings include the following:

  • Companies’ compliance with current modern slavery reporting laws has been inadequate;

  • Modern slavery reporting requirements aimed at encouraging businesses to address forced labor in their supply chains have overall failed to bring meaningful improvements for workers;

  • Companies have generally failed to recognize that forced labor and human trafficking arise out of a context of widespread labor abuses and to investigate and address how their own business practices and operating models can create the conditions for such abuses;

  • The breadth and quality of information disclosed by companies does not reflect effective human rights due diligence processes, and is not detailed enough to allow civil society to adequately monitor and engage with companies in order to find effective measures to protect workers and prevent abuses; and

  • Governments’ monitoring and enforcement mechanisms are too weak to lead to effective corporate responses to and adequate reporting on modern slavery risks.

The report recommends additional and improved legal requirements, better company reporting standards, and stronger enforcement and monitoring mechanisms, including the following:

  • Modern slavery reporting requirements should provide for consequences for noncompliance, including financial penalties, corporate liability and exclusion of non-compliant companies from public procurement;

  • Governments should establish an independent body to monitor compliance and to assess the quality of modern slavery disclosures;

  • Company reporting should be risk-based and include information on corporate policies and processes in place to respond to risks of forced labor as well as on the outcomes and results of such measures; and

  • Governments should aim to move toward mandatory human rights due diligence legislation, with modern slavery laws being one tool amongst others to address forced labor and human trafficking.


Please contact Tony Franquiz at 202-374-5393 or to be connected with ICAR Legal and Policy Coordinator Marion Cadier for comment/interview about the report and the issue of modern slavery generally.

Please contact Emily Kenway at (+44) 7931 687 890 or to be connected with FLEX Executive Director Caroline Robinson for comment/interview about the report and the issue of modern slavery generally.



About ICAR

The International Corporate Accountability Roundtable (ICAR) harnesses the collective power of progressive organizations to push governments to create and enforce rules over corporations that promote human rights and reduce inequality.


About FLEX

Focus on Labour Exploitation (FLEX) works to end human trafficking for labor exploitation. To achieve this, FLEX works to prevent labor abuses, protect the rights of trafficked persons, and promote best practice responses to human trafficking for labor exploitation through research, advocacy and awareness raising. FLEX is a registered charity based in the U.K.