The Modern Slavery Act (“MSA”) was introduced in the United Kingdom in October 2015 introducing criminal offences of slavery, servitude, forced or compulsory labour and human trafficking. However, its most profound impact has been to drive a change in global business behaviour by introducing, pursuant to s54, a disclosure and transparency reporting approach. This requires a commercial organisation supplying goods or services (carrying on a business, of part of a business, in the UK with a turnover of £36M) to produce an annual statement on steps taken to combat slavery and human trafficking not only to a business’ direct operations but also their supply chains.

Following the MSA a legislative trend utilising due diligence and disclosure obligations to further responsible business conduct has developed and been reinforced by developing case law and test cases seeking to hold businesses accountable for social/human rights related issues. The launch of global Principles in 2018 for governments to use as