The Committee considered the undernoted report:
“1.0 Purpose of Report or Summary of main Issues
1.1 The purpose of this report is to provide Members with the updated annual Modern Slavery Transparency in Supply Chains Statement to meet the obligations of the Modern Slavery Act, 2015 and an update on the related corporate action plan.
2.1 It is recommended that the Committee:
· Note the updated annual Modern Slavery Transparency in Supply Chains Statement (the ‘Transparency Statement’).
· Approve the addition of the Transparency Statement to the UK Government’s online registry.
· Note the progress made on the action plan.
3.0 Main report
The Modern Slavery Act 2015 (the ‘Act’) aims to address slavery and trafficking by enhancing support and protection for victims, giving law enforcement the tools needed to target today’s slave drivers and ensuring perpetrators can be severely punished. It also includes a provision in Section 54 to encourage organisations to ensure their supply chains are slavery-free, known as the Transparency in Supply Chains arrangements (‘TISC’).
3.2 Key Issues
The Council has voluntarily published an annual Transparency Statement on our website since 2015. This sets out what the Council has done to ensure there is no modern slavery in its supply chains or any part of its business.
This year, the annual Transparency Statement has been reviewed by Commercial and Procurement Services, the Council’s Safeguarding Officer and the Equality and Diversity Officer and has been refreshed to reflect current guidance on its content. An updated version for 2021-22 is set out in Appendix 1.
3.3 Recent changes to the Transparency Statement requirements
The TISC provisions currently apply to commercial organisations, however, in recent years both the UK Government and the Northern Ireland Department of Justice have reviewed and consulted on these provisions and their potential application to the public sector:
· In July 2018, the Home Secretary undertook an independent review of the Act and made recommendations, one of which was to strengthen Section 54 by extending the requirement to publish Modern Slavery Statements to government and the public sector.
· In July 2019 the UK Government launched a consultation on measures to strengthen the TISC arrangements and published its proposals on how it planned to take this work forward. Many of the proposed changes will require legislative change which has not happened to date. The proposed changes would see a strengthening of the TISC arrangements for commercial businesses, and would, for the first time, extend them so they apply to the public sector.
· In January 2022, the Northern Ireland Department of Justice (‘DOJ’) published its report, summary of responses and next steps in response to its consultation on TISC. It found that overall, there is widespread support for the strengthening of TISC arrangements.
3.4 Approach to Modern Slavery in Northern Ireland
In October 2022, in accordance with Section 12 of the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015, (as amended by the Justice (Sexual Offences and Trafficking Victims) Act (Northern Ireland) 2022), the DOJ launched a public consultation on a new three-year draft Modern Slavery and Human Trafficking Strategy. This is a multiagency collaboration, with actions to be delivered by members of Northern Ireland’s Organised Crime Task Force, NGO Engagement Group and other agencies working to address modern slavery and human trafficking.
The DOJ noted in its consultation that the UK Government plan to make additional changes to the TISC provisions in the Act when parliamentary time allows. The additional changes that the UK Government plan to legislate for include:
1. Reporting on specific topics;
2. Publishing the MS statement on a public registry;
3. Setting a deadline for submitting a statement annually;
4. Extending the requirement to publish a statement to public sector organisations with a turnover of over £36million; and
5. The introduction of financial penalties for those that do not publish a slavery statement.
3.5 It should be noted that the Legislative Consent of the Northern Ireland Assembly will be required to extend any UK Government changes to Northern Ireland.
Alongside the consultation, the DOJ published a progress report on the commitments laid out in the 2021-22 Modern Slavery and Human Trafficking Strategy for Northern Ireland. The Progress Report states in part that the DOJ ‘will engage further with public sector procurement leads once the additional measures to strengthen TISC are progressed in legislation and will become mandatory for all businesses with an annual turnover of over £36million.’
3.6 In March 2021, the UK Government launched an online modern slavery statement registry. Since its launch, over 7,000 statements have been submitted covering over 23,350 organisations on a voluntary basis.
Members asked to approve the addition of the Belfast City Council Transparency Statement to this registry.
3.7 Action Plan
In October 2021, Council approved an action plan to tackle modern slavery to be taken forward by various departments. This was based on guidance from NILGA. An update on the proposed actions is set forth in Appendix 2.
Members should note that an initial awareness session for relevant Belfast City Council managers on recognising Modern Slavery and Human Trafficking was held on 17 November by the Department of Justice.
The Governance & Compliance Manager co-ordinates an annual report on progress to be brought to CMT and the Strategic Policy & Resources Committee.
3.9 Financial & Resource Implications
The implementation of the action plan will involve staff from City and Neighbourhood Services, Legal Services, Governance & Compliance Services, Commercial and Procurement Services, Corporate HR and Marketing and Corporate Communications.
3.10 Equality or Good Relations Implications/Rural Needs Assessment
Any equality, good relations or rural needs implications will be identified using the council’s usual screening process.”
The Committee adopted the recommendations.