The launch of the U.K. Slavery and Human Trafficking (SHT) Transparency Register in April 2020 marked a new phase in the country’s efforts to promote corporate accountability in addressing modern slavery risks. For many retailers and manufacturers, this development was long anticipated, but the reality of interacting with a live, public-facing portal brought with it both opportunities and practical challenges. There had been, over the years, no shortage of debate about the effectiveness of the Modern Slavery Act 2015, especially its reporting provisions. Some felt that the absence of a centralized, easily searchable repository had, until now, limited the Act’s power to drive meaningful change. That gap was now, at least partially, being addressed.
For companies preparing to upload their modern slavery statements to the register, the first task was relatively straightforward: ensuring that the latest approved statement was available in a format acceptable to the portal. PDF uploads were the norm, although some firms experimented with adding hyperlinks or embedded data tables. But even at this early stage, firms encountered decisions that went beyond the merely technical. What level of detail should their statements contain, knowing they would now be housed in a register designed for direct comparison? How should they present areas of uncertainty or ongoing risk, given that greater transparency might invite greater scrutiny—not just from regulators but from civil society, investors, and even consumers?
The portal itself, designed to be intuitive, required users to enter key metadata alongside their uploaded statements. This included the reporting entity’s legal name, registration number, fiscal year covered, and the date of board approval. Here, accuracy was essential—not only for compliance but to ensure the statement could be found and correctly linked within the growing database. Some firms discovered, rather belatedly, discrepancies between what their internal records showed and what was held at Companies House, leading to a flurry of corrections before uploading could proceed. It became clear that transparency reporting was not just a matter for sustainability teams but also for legal and corporate governance functions.
Once uploaded, attention turned to how the statement could or should be linked to supplier-level risk assessments. Here, the availability of NGO data played a pivotal role. Several well-established organizations had, by this time, published detailed risk maps and databases highlighting sectors, regions, and even specific supplier categories associated with elevated modern slavery risks. The challenge for companies was integrating these external sources with their internal supplier data in a coherent and defensible way. Some took a cautious, stepwise approach, initially linking only to broad sector-level assessments. Others went further, seeking to map individual suppliers to specific risk ratings where data permitted. There was no uniform method, and that perhaps reflected the diversity of supply chain configurations and the varying levels of data maturity across firms.
In practice, using the open portal to ensure accurate, searchable disclosures meant more than just filing a document and moving on. It required thinking about how external stakeholders would engage with that information. Would investors searching the register see a clear, well-organized statement that reflected genuine effort? Would NGOs find evidence that their reports and risk data had informed corporate action? These questions were not always easy to answer, particularly for firms at the start of their transparency journeys. And in some cases, the answers prompted internal reviews, as companies realized that what looked acceptable in a pre-register world now appeared lacking under this new spotlight.
The process of linking SHT statements to supplier-level risk assessments raised its own set of issues. For one thing, not all NGOs used the same criteria or methodologies in assessing risk, which led to some awkward decisions about which sources to prioritize. In some instances, the very act of choosing a particular data set over another could be seen as a tacit endorsement of its underlying assumptions—something that not all companies felt comfortable doing. Moreover, supplier risk profiles were often fluid, changing as sourcing strategies evolved or as new information emerged. Maintaining up-to-date linkages between the statement on file and the dynamic reality of the supply chain added a further layer of complexity.
What emerged in these early months following the register’s launch was a sense that modern slavery reporting was shifting from a largely narrative exercise into something more data-driven, more interactive, and arguably more consequential. Companies that had previously treated the annual statement as a compliance box to tick began to see it, or at least were encouraged to see it, as part of a broader transparency ecosystem. There were, inevitably, growing pains. Some firms struggled with technical issues in the portal’s early days. Others found that what they had considered adequate disclosure now appeared thin in comparison to the emerging best practices. And still others grappled with internal tensions—between legal caution, operational realities, and the aspirations of sustainability teams seeking to push the boundaries of disclosure.
As with so much in the field of supply chain transparency, the introduction of the register was not a silver bullet. But it did change the terms of engagement. It placed statements side by side, made them easier to find, easier to scrutinize, and harder to ignore. And as companies navigated this new environment, they did so with the growing realization that transparency, once optional or peripheral, was becoming a central element of corporate responsibility and risk management. The full implications of this shift would, in all likelihood, take years to unfold, but the direction of travel was becoming increasingly hard to dispute.