Modern Slavery and Human Trafficking in the Financial Services Sector
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Key takeaways:
- In September 2021, Dame Sara Thornton, the United Kingdom’s Independent Modern Slavery Commissioner, issued a report (the “September report”) setting out her recommendations for the financial sector in the United Kingdom to take concrete steps to address modern slavery and human trafficking (“MSHT”) up and down the supply chain and in its activity across all operations.
- In the September report, Dame Sara Thornton makes five recommendations addressed at the financial sector to ensure that they integrate MSHT risk across all its business processes. These recommendations include: (1) risk management and mitigation, (2) systems for sharing, (3) collective action, (4) collaboration on electronics supply chain, and (5) the need for financial institutions to report on their investment and lending portfolios under Section 54 of the Modern Slavery Act.
- The September report builds on an earlier study, a yearlong research and outreach project led by the Commissioner, the financial crime consultancy Themis, and the TRIBE Freedom Foundation, seeking to draw attention to the issue of MSHT, highlighting the linkages within the financial services industry, and sounding a call to action for the industry as a whole. This initial research uncovered the low levels of awareness of the prevalence of MSHT and the insufficient procedures put in place to monitor MSHT in the financial sector.
- This report sits alongside proposed legislative and regulatory measures in various jurisdictions to strengthen the corporate response to modern slavery and human trafficking in their value chains.