October 30, 2019, by htaylor

New Research: Compliance up but quality down – the concerning lack of engagement in modern slavery reporting from the UK agricultural sector


A recent report from the Rights Lab at Nottingham has found that less than 50% of agricultural businesses in the UK are compliant with the terms of the 2015 Modern Slavery Act, and that the quality of the reporting is low. This is a cause for concern for a sector with the fourth highest proportion of victims of forced labour worldwide.[1]

The study, led by Andrew Phillips and Dr Alex Trautrims from the University of Nottingham’s Rights Lab, assessed the number and quality of modern slavery statements from 44 UK agricultural businesses and identified some concerning results.  Looking at both compliance[2] and the quality of ‘Transparency in Supply Chains’[3] (modern slavery) statements, the report shows that the UK’s Modern Slavery Act is not inspiring the race to the top it was hoped for, and that engagement of the sector in this issue is simply not where it should be. Whilst 89% of agri businesses now have some form of statement published (compared to just 51% in 2017[4]), only 46% of these actually meet the Act’s minimum requirements, meaning that overall only 41% of the agricultural sector is abiding by the terms of the legislation.

More worrying still is that the quality of reporting (including commentary on due diligence processes, policies, training and effectiveness measures) is dropping year on year. This average is mostly driven down in part by companies publishing weaker first statements, however this highlights that companies are not attempting to learn from their industry peers, nor engaging with the proliferating amount of support and guidance available. Reporting tended to be ‘tick-box’ in nature with plenty of references to ‘zero-tolerance approaches’, but was disappointingly sparse on commitments to take concrete actions. Effectiveness measures and performance indicators persist as the least well addressed area – a critical element if year on year improvement in addressing modern slavery is to be achieved.

Those working directly in agriculture, or indeed those buying from agri businesses, may be well aware of the increased risk of modern slavery in such operations. Reliance on low skilled seasonal labour, coupled with increasing cost price pressure from above, make the workforce in agri businesses more susceptible to exploitation. With this in mind, it’s crucial that the sector takes modern slavery reporting seriously.

Whilst the study indicates clear room for improvement from the agricultural sector in general, it also highlights a pressing need to strengthen the legislation to address the current lack of government enforcement and oversight of modern slavery reporting. The study insightfully compares reporting on modern slavery with Gender Pay Gap (GPG) Reporting, showing the stark difference that effective regulation, including mandatory reporting requirements, can make in a comparable area of corporate social responsibility: 87% of companies with a responsibility to report under the GPG regulations did so on day one of the first year of reporting, versus a mere 19% compliance rate for reporting under the Modern Slavery Act by the agricultural sector. This underscores the importance of ensuring compliance and improving the quality of statements, the main focus of the Independent Review of the Modern Slavery Act[5] on the issue of transparency in supply chains.

Given the risk of exploitation and abuse that workers in the agricultural sector face, urgent action is required from businesses and policy makers alike to stop the downward trend identified in this research. To read our full list of recommendations, you can access our Briefing for Policy Makers here, our Business Briefing here, and the study is available in full here.

If you’d like to know more about the Rights Lab or find out how we might be able to support your business in its efforts to tackle modern slavery, get in touch: rightslab@nottingham.ac.uk.


[1] International Labour Organisation. (2017). Global Estimates of Modern Slavery: Forced Labour and Forced Marriage. Figure 9. http://www.ilo.org/wcmsp5/groups/public/—dgreports/—dcomm/documents/publication/wcms_575479.pdf

[2] The requirements considered here are that the statement is signed by a director, approved by the board and linked from the company’s homepage

[3] Section 54 of the Modern Slavery Act

[4] See the first report of this kind undertaken by the Rights Lab in 2017, at https://www.nottingham.ac.uk/research/beacons-of-excellence/rights-lab/mseu/mseu-resources/2018/november/modern-slavery-act-and-agriculture.pdf https://www.nottingham.ac.uk/research/beacons-of-excellence/rights-lab/mseu/mseu-resources/2018/november/modern-slavery-act-and-agriculture.pdf

[5] Independent Review of the Modern Slavery Act 2015: Final Report. https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/803406/Independent_review_of_the_Modern_Slavery_Act_-_final_report.pdf

Posted in Ending SlaveryMSEU