What is the modern slavery act 2015?
The Modern Slavery Act will enable law enforcement to tackle modern slavery by providing law enforcement agencies with tools to fight the perpetrators and strengthen protections for victims. In addition, the Act includes a ground breaking transparency in supply chains measure which requires any organisation carrying on business in the UK and with a total turnover of £36M or more to produce an annual statement on the steps they are taking to prevent modern slavery in their supply chains and own organisation.
Do I have to report every year?
Yes, if you're a trading company with a footprint in the UK and your turnover is £36M and over. The full in-scope definition is within the wording of Section 54 of the Modern Slavery Act. However many companies have told us that they will be reporting even with lower turnovers. This makes us very happy.
I want to join but we don't yet have a statement to share. What should I do?
Join us! We work on membership subscriptions, and with us you will get 12 months access to ongoing help making sure your compliance is actually making a difference, and finding more ethical clients who feel the same way. You should start by signing up for the user authentication process. This means that your identity (and those of any other team members who need to join you) can be authenticated in advance, so that when you do actually have a statement to share, you can do so without delay.
How much will membership cost?
You can submit your company statement anonymously without for free. However this will also mean that anyone from outside of your company can do the same. In the spirit of the legislation, making your submission public instead of anonymous would make a far greater impact.
So you can join as a Non-Contributing Affiliate Member FOR FREE if
- you have an annual turnover of less than £36M, or
- if you are over £36M turnover and do not have available budget to contribute £200+VAT a year for a Contributing Membership, or
- if you are a charity or
- if you are a public sector body, for which there is a special account at https://public.tiscreport.org/.
We do some basic online partial authentication for free but this is not full authentication (which is available as an option for a timestamped membership and submission).
When you are ready to subscribe as a paid member (12 monthly), we have a number of subscriptions to suit your needs and desired level of involvement, starting at £200+VAT per year (all excluding credit card handling charges,sorry).
Our company would also like to contribute in other ways to combat slavery. Who do we talk to in order to take this forward?
There are many ways in which you can get involved with our various transparency initiatives and projects. Take a look at some of those in the pipeline at https://techfund.tiscreport.org/. If you want to offer more specific support (from promotional support through to funding specific anti-slavery initiatives) please use our contact form to get in touch, and someone will be back in touch with you.
Why do I have to upload my statement to you?
You don't have to! But if you did so as a contributing member you'd be able to make use of our AI statement audit to check for technical errors and help improve it. We have developed an international, open data register for filing all MSA statements, which in turn will be searchable by members of the public. By submitting your Slavery and Human Trafficking statement to us, we will be able to independently verify that you are in compliance with section 54 of the Modern Slavery Act 2015. We will also publish a live index of business performance by sector, including those who fail to report. Businesses who file their statement with us will be able to include this action as one of the steps they have taken to support the UK in fighting modern slavery. In addition, as a civil society register complying with government register guidelines, we will provide you with a unique tiscreport.org link to the statements you upload, which will also contribute to your transparency efforts for your next statement.
I've found another reporting portal that claims to be the central modern slavery statement register, and so I uploaded my report there. Why do I need to upload my report with you too?
There is NO single central repository. The Government (including Minister Sarah Newton, Baroness Williams, Lord Keen of the Home Office) has clearly and repeatedly stated that there will be no choice of a single solution and that the open market will be allowed to flourish around modern slavery data. If you are worried about having to choose a register/repository and have no preference on approach then we recommend that you support all of them. We have built in a user-controlled function to enable members to submit of statements to other registers from within tiscreport, in an effort to join forces with other open data initiatives. We need more collaboration and openness, not more silos.
The TISCreport register is not only increasing transparency with a data driven approach, it is the only modern slavery statement register partnering and funding the official UK Modern Slavery Helpline and Resource Centre, tendered by Polaris to our award winning charity partners Unseen. It is the ONLY register in an official partnership with the helpline, and as such supporting it by becoming a member will in itself be an action you can report in your future statements. Additionally, because we are the only register measuring company compliance quantitatively, you will be able to check your supply chains for non-compliance through our systems. This is not something you can currently do anywhere else.
Our own register is neutral with no ranking or tiering, and our focus is on data integrity to allow others to access and analyse on their own sites. Other repositories have chosen to rank and tier (if not on their own sites, then on others), which some businesses will find valuable in holding them to account. They are also far more geared towards use by the public, which is something our data enables our other partners via API. Ours is an international open data register that also enables easy compliance checking. With data analysis techniques and additional sources of supply chain risk data we aim to provide businesses access to best practice from their sectors. If this approach and these features are valuable to your business, then we would love for you to join us.
When do we need to submit our statements?
There is no deadline, however Home Office guidance recommends publishing your statement within 6 months of the organisations year end. We would urge companies to file as soon as they are able so that their statements can be put to good use sooner. Tiscreport will show you which of your suppliers are due beyond their recommended due date through the supplier dashboard.
Why can't we just upload our statements to our own websites?
All organisations must upload their statement on their own website with a link to that statement on the home page in a prominent place. However, the central repository will increase transparency by providing a central place for analysis of your reports to feed into future policy and intelligence on slavery and trafficking. By having all the data in one place you are helping to combat slavery in partnership with others in your sector. We also are able to provide supply chain transparency data consultancy and support within your sector specialisms, and enable your company to make progress much faster than working in isolation.
Are you an official partner of the Home Office for this reporting?
No. We are a social enterprise and charity partnership aiming to use your statements to end modern slavery within our lifetimes. We announced, at the Home Office TISC event on 21st March 2016, that we were setting up a central repository working with the UK Modern Slavery Helpline, and Resource Centre. We continue to support and report our findings via the UK Home Office Transparency In Supply Chains Strategy and Implementation Group.
Where can we find help to write our statement?
TISCreport does not itself provide any compliance consultancy services. We are neutral and allow all members to play their parts through their own skills and services to raise standards and awareness of supply chain transparency. However do we signpost to training and support line services via our members and partners. Or, if you have everything in hand you can simply use our statement submission service. The resource centre we are developing with CIPS and anti-slavery community members to support the national helpline and the register will also provide access to advice and support to organisations in complying with the Act and writing their statements via our highly competent consultancy members and partners.
I'm sold. How do I submit a statement for my company?
Fantastic! It's simple. Register on our site. Once you have verified your account by clicking the link in the email we send you, you will be able to add your company to your workspace by click the "Workspace" button. Search for your company in the search box that appears, and then "Add to workspace". This will take you to the workspace with all your companies listed. Select the company and you should see a list of todos. Click "Request Access" to be authenticated for being an administrator for that company. This will trigger a user authentication process against that company which will start as soon as you've paid the annual membership fee (starting from free). You'll need a credit card for paid membership (starting from £200+VAT). User authentication can take up to five working days (just like Companies House), but you will then be sent the access code for your company.
We have a group of companies. Can I upload modern slavery statements for all of them through one account?
Companies that are subsidiaries over £36M turnover need to ensure that they have a Modern Slavery Statement that applies to them, either via their Group statement or via their own statement.
There are three ways to add statements for your subsidiaries and two of them are free.
Anonymous submissions: simply search for your company using the public search on the home page of https://tiscreport.org/
E.g. Starbucks: https://tiscreport.org/company/gb/02959325
Paste in the link of the statement and follow the instructions as “a member of the public”. Your statement will then go into a queue for processing, by both automated checks and by human eye.
Submission By Affiliate membership (also free):
a) Register via: https://tiscreport.org/user/register
b) Click on your workspace: https://tiscreport.org/workspace
c) Add your company, click “Select a Subscription to Validate & instantly save changes”
d) click “Affiliate Free account” and validate as affiliate using one of the two methods outlined.
e) Upload your statement
f) add your next subsidiary and repeat free authentication method.
Submission by paid membership (extremely good value for companies taking transparency seriously!):
The pricing structure for this is £200+VAT for up to two subsidiaries, £400+VAT for up to 5 companies, £1500+VAT for up to 20 subsidiaries.
a) Register via: https://tiscreport.org/user/register
b) Click on your workspace: https://tiscreport.org/workspace
c) Add in your leading Group company and click “Select a Subscription to Validate & instantly save changes”
d) Select the appropriate membership for your group
e) For groups with 10 plus paid memberships, send us your list and we will set up your workspace for you and guide you through our simple authentication service!
f) Take a look at the compliance of your suppliers so that you can report your baseline for next year’s MSA statement.
Will my company or statement be ranked or tiered against other companies or my competitors by tiscreport.org?
No. We are providing a neutral platform for all business members to file their transparency statements. Once shared with tiscreport.org, your statement is made available to everyone publicly. We want your statements to inspire positive actions in other companies because we know slavery exists in every supply chain. We will do all we can to achieve our end goal by working in partnership with our members, and providing useful tools and resources in order to help our members do so.
Why isn't the UK government setting up a public register through Companies House or BEIS?
Whilst we can't speak for the UK government, we were told that a civil society solution was expected to take on this provision, and tiscreport was created as a social enterprise to do exactly this. As the only register partnered with the UK Anti-Slavery Helpline (50% of all membership fees goes directly to Unseen), we hope that this self-sustaining model of provision provides the best of both worlds without impacting on the taxpayer.
How are you ensuring that there are no conflicts of interest between the business members you represent and your work and donations towards preventing slavery in supply chains?
The first and most important thing we've done is to be an open data initiative. This means that our data is available for all to scrutinise, correct and add to. No matter what happens to us, our data will remain available to all under open data licence.
The second thing we've done is set up three tiers of scrutiny by a three tier governance structure: our overarching governance board, our business advisory panel and our data strategy board. We report to all three, and these in turn monitor everything we do, from our partnerships, to setting best practice to how we administer our open data.
The third step is becoming a b-corp. As a social enterprise by b-corp, we have signed up to levels of business transparency usually required of significantly larger companies.
We set up tiscreport as a social enterprise to end modern slavery in partnership with all those who wish to work with us. We do not, and never will, provide a safe haven for deliberately bad actors, and are wholly focussed on creating transparency tools and providing good quality data to make doing the right thing really easy. We hope that you will join us too.
Are charities required to comply with section 54 of the modern slavery act?
From our register we can see a number of very large charities, who we assume to have large legal departments, erring on the side of either caution or just doing the right thing. For that reason we have ensured that we hold the most recent charity register data from the Charities Commission within our platform. In terms of legal opinion, there are articles from legal professionals who also seem to feel that many charities and their subsidiaries are subject to section 54 compliance. We've linked to one of them here as an example. We have no affiliation with this law firm and recommend that if you are a charity, you get your own independent advice on your status:
There is a legal opinion that if a charity is subject to the UK Goods and Services Act that they are also subject to the Modern Slavery Act if their turnover is above £36M. Often charities have trading subsidiaries in order to deal with this and the Government guidance on charities and trading explains this very well.
Are schools required to comply with the modern slavery act?
There have been discussions around this and it really depends on whether or not the school is over the £36M turnover threshold and trading goods and/or services (e.g. gym memberships, school uniforms etc).
As we are not legal experts we have found an article or two from those within the profession that might help:
There are many schools and school trusts that have decided to produce a modern slavery statement as a matter of best practice, alongside those who are deemed to be trading. You can have a look at them here: