Anti-bribery and corruption in Corporate Regulation

Anti-Slavery Day: fighting modern slavery

Modern slavery

Slavery still exists in our modern society. Anti-Slavery Day on October 18th is a reminder to all businesses that they have an obligation, and indeed the power, to take action to improve the ability of employees, customers and suppliers to fight modern slavery.


So what is modern slavery?

Modern slavery is an umbrella term that encompasses the offences of human trafficking and slavery, servitude, forced labour or compulsory labour. According to the Global Slavery Index, an estimated 40.3 million people were victims of modern slavery in 2016. The International Labour Organisation ("ILO) reports human trafficking as the third largest illicit money making venture, generating around $150 billion annually, behind only drug dealing and the arms trade.


Evolving requirements in relation to Modern Slavery

In 2015, the UK Government introduced the UK Modern Slavery Act (MSA), which aims to eradicate slavery linked to UK markets. Part 6 (section 54) of the Act, relating to transparency in the supply chain, seeks to address the role of businesses in preventing modern slavery across their operations and supply chains through mandated reporting.

As a result of a 2018 Independent Review of the Act, the Government committed to updating its guidance for reporting companies. This is designed to improve the quality of statements, embed modern slavery reporting into business culture, and increase transparency. The updated guidance will:

  • Make clear the need for organisations to strengthen human rights investigations or ‘due diligence’ activities beyond 1st and 2nd tier suppliers over time; and
  • Encourage organisations to include details of the specific due diligence steps they intend to take in future.

A recommendation to make certain elements of the existing guidance mandatory was subject to public consultation held between July and September 2019. If adopted, this recommendation would require companies to report against six areas including organisation structure, business and supply chain, policies in relation to slavery and human trafficking, due diligence processes, risk assessment and results, effectiveness and training, all within their annual reports.


What should you be doing?

Businesses will face increasing regulatory obligations in the area of modern slavery, so we recommend reviewing your current approach against the proposed guidelines and leading practices for your industry. If you identify gaps, you should establish programmes that are specifically tailored to the risk faced by your organisation.


How can Deloitte help?

We are a team of experts specialising in human rights and modern slavery who work with clients to identify, assess and mitigate risks of modern slavery and other ethical risks within their operations and supply chain. We would be happy to have a discussion with you if you have questions about how to assess and manage modern slavery in your organisation.


For any further information, please contact:

Emily Cromwell

Director | Deloitte LLP

+44 20 7007 0825


Pip De Fonblanque

Manager | Deloitte LLP

+44 20 7303 3866






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Posted on 17/10/2019 | 1 Comments

Bring some science to your HSE strategy

The final part of the HSE management – Comply, improve, excel series

Blog 3

How are your Health, Safety and Environment (HSE) plans formulated? Audit results, past incident history, a known legislative non-compliance issue that needs to be bridged?

These inputs can all point to a body of work sufficient to keep the organisation ‘busy’ on HSE – but will they move the needle in keeping people safe and healthy, and reducing impact on the planet? And whilst we’re talking about it, who designed those plans?

Stepping out of HSE management – let’s think about the Hotel Industry. Our strategy is to grow, we have some capital, and want to build a new hotel to generate more revenue. We know the outlay and can research average room rates for a given location, before we build our hotel and operate it against a planned P&L – in short, we can approach the project with a level of confidence, and measure it’s success.

Would you sign off the investment if you didn’t know how much you might be able to charge for a room, or what the staff costs to run the hotel might be? Further still, would you sign off the investment because an individual "specialist" told you it was the right thing to do?

These questions might sound a little daft – but for many organisations, it’s a fair reflection of how planning on HSE happens. HSE outcomes are notoriously difficult to measure, and often (likely unwillingly) the Head of HSE is tasked with coming up with a plan on behalf of the organisation, and trusted in their proposed plans because they’re the "specialist".

"Advanced data analysis is being used throughout industry to achieve things previously thought impossible"

It would seem better for all concerned to bring a little science to the equation.

Measuring HSE success continues to challenge organisations; but away from hard measures, there are many opportunities to improve the analysis of HSE-related information. Advanced data analysis is being used throughout industry to learn more about what drives performance, and beyond learning – even extending into using that analysis to automate decision making.

On a less grand scale, but no less impressive, is the ability to use data to support effective planning and monitoring of HSE management. Combining disconnected data sources can reveal previously hidden correlations, which hold the potential to better target factors which contribute to increased HSE risk, with greater accuracy, and less ‘gut feel’.

In our fictitious hotel company, we might choose to combine data relating to accidents, audits, training information, occupation levels and online customer feedback reviews to help highlight statistically significant patterns. As illustration, we might learn that;

Hotels with declining customer feedback scores are more likely to have a spike in accident occurrences

Good audit scores may tally with a significantly lower incident frequency. However, when incidents do occur they tend to be much more severe in nature than average; or

Completion of current safety training has no statistically significant impact on audit scores or incident occurrence.

"The application of data analytics provides a valuable source of data driven insight."

These illustrative insights might have previously existed as ‘hunches’, but few might be brave enough to step forward and declare that current safety training arrangements are ineffective – traditionally it’s easier to ‘do more’ HSE work rather than to challenge the effectiveness of what is in place already – the possibilities provided by data analytics could change that.

There are a number of ways that organisations could benefit from using analytics in making decisions around HSE; on its most basic level, it may be best used as a tool to:

  • Prove or disprove existing hypothesis ("we’ve got a hunch, but haven’t ever felt certain"); or
  • Generate new insight through exploration ("we think we’ve tried everything, where should we turn next to better manage risk").

Is your strategy going to deliver best impact?

Those responsible for HSE strategy generate the greatest impact by making good choices. Making the most of data to support consistently great choices can heighten individual impact, better prioritise organisation resources, and most importantly support a safer and healthier environment.

  • How did you arrive at your current priorities – who was involved in prioritisation of effort, and is there any room for hunches that might be derailing the most effective use of resource?
  • Are there any long-standing hypotheses that your organisation holds dear around HSE, that have never been proven to be true? Could the application of analytics support a clear conclusion?
  • How targeted is your approach to HSE? Does your business rely on blanket approaches to topics such as training, auditing and assessment – could some science help you customise that approach without exposing the organisation to unnecessary risk – and how might that customisation help you excel in creating a safer environment, with the same or less resource?


For any further information, please contact:

Callum Irvine

Director | Deloitte LLP

+44 20 7303 6277

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Posted on 30/07/2019 | 0 Comments

Words cost: the value of plain language

Plain language
Potential net annual cost savings of £250,000 or more should be music to corporate ears. Those ears however seem resistant to the siren song of plain language for regulatory compliance communications.

Evidence shows that small investments in clearer messages save significant time (and therefore money), and improve reader understanding and compliance. For example, in the US Federal Express revised its ground operations manuals, which staff had to search for an average of 5 minutes to find information, with only 53% then finding the right answer. Average search times with the new manuals fell to 3.6 minutes, with an 80% success rate and conservatively estimated annual savings of $400,000. [1]

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Posted on 15/06/2017 | 0 Comments

Failure to prevent offences: are they adequate or reasonable?

The second UK corporate offence of failing to prevent a crime committed by an associated person has just been introduced by the Criminal Finances Act 2017, covering facilitation of tax evasion and following in the tracks of the similar UK Bribery Act 2010 offence.

Most corporates would agree that aiming to prevent associates from committing crimes within the business is the right thing to do, and that the defences of having adequate procedures (for the UKBA) or reasonable procedures in all the circumstances (for the CFA) appear sensible. So this approach could provide a sound solution to the problem of corporate criminal liability. It should, however, be used with caution.

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Posted on 15/06/2017 | 0 Comments