Anti-slavery day reflections: governance and accountability

As a governance practitioner and doctoral researcher, every year, as Anti-Slavery Day approaches, I find myself reflecting on the gap between awareness and action. In the governance world, we talk about ESG, ethics and transparency yet modern slavery remains one of the most persistent blind spots when it comes to corporate accountability for businesses. Following this year’s Anti-Slavery Day, I want to surface on how far corporate governance has come and how far it still has to go in relation to this topic.

I hope that those of us in governance, company secretaries, risk professionals and scholars commit to making transparency transformative and not transactional. Because I believe, in the end, the legacy of good governance will not be measured by how well we disclosed our values but how well we protected them.

Over the past years, I have written several articles exploring the connection of modern slavery, governance and board accountability, examining how regulatory shifts, reporting expectations and ethical risks influence it. 

From my perspective and from what I am observing through my doctoral research, the challenge lies not in the absence of policy but partially in the depth of governance follow-through.

After looking at some numbers, it appears that the National Referral Mechanism (NRM) recorded 5,690 potential victims of modern slavery in just one quarter (April–June 2025) in the UK. This number is a 32 % increase from the same period in 2024, and the highest quarterly figure since records began in 2009 (UK Home Office, 2025). Across all of 2024, the UK saw 19,125 referrals to the NRM, an all-time high (Hope for Justice, 2025). The International Labour Organisation (ILO) estimates that 50 million people globally live under conditions of modern slavery, 28 million in forced labour and 22 million in forced marriage (ILO, 2024). These figures don’t just describe a crisis that impacts multiple jurisdictions, they also signal a corporate governance test. Exploitation, particularly in business supply chains, threads through legitimate supply chains and service contracts of multinational businesses.

The UK’s Home Office provided an update in 2025 on the Modern Slavery Act guidance (Section 54) and decided to tighten expectations around corporate transparency statement. The Act now specifies that organisations should identify tangible actions, risk assessments and performance measures (UK Home Office, 2025 I think a link to the site could be beneficial but leave it to you). 

Similar trends are reshaping the governance and compliance landscape all over the world. In the European Union, the EU Corporate Sustainability Due Diligence Directive (CSDDD) is incorporating mandatory human rights due diligence into European Law. In Australia, the Modern Slavery Act review is moving toward civil penalties and also much stronger enforcement powers. Lastly, in the US, the Uyghur Forced Labour Prevention Act continues to restrict imports and force multinational businesses and their boards to constantly revisit their procurement practices. I think we can conclude that the message is consistent across jurisdictions: voluntary disclosure has had its day. We are now entering the era of enforceable accountability, where businesses must own the narrative.

A silent yet strong change is taking place within boardrooms. The issue of modern slavery is no longer seen as a niche compliance topic, it is becoming the fundamental indicator of responsible governance.

The tone is changing, directors are asking sharper questions, committees are demanding evidence rather than assurances and modern slavery risk is being discussed alongside reputation. Encouragingly, a number of companies in the UK and across the globe are redefining the way good governance should appear in this area.

More and more boards are incorporating modern slavery within the regular rhythm of their governance cycle and including it as a quarterly or annual agenda item for discussion. Some leading companies now require regular updates from procurement and compliance teams detailing audit findings and remediation progress, if applicable. A useful example is Unilever which publicly discloses its approach to human rights governance through its Business Integrity Committee, meeting quarterly to review progress across modern slavery, living wages and supply chain risks (Unilever Human Rights Report, 2024).

Strong boards know that ownership is clarity. Audit and Risk Committees are increasingly becoming the leader of overseeing the effectiveness of due diligence processes, while Sustainability or Ethics Committees focus on the result of stakeholder engagement and remediation.

One of the most significant shifts in governance practice is the adoption of independent assurance to validate modern slavery data. According to the Walk Free Foundation’s 2025 review, 80% of UK companies publish modern slavery statements, however a quarter of them fails to meet minimum reporting standards and fewer than 10% commission external verification (Walk Free, 2025). To bridge this difference, leading firms are using digital due diligence platforms and AI-driven supply chain mapping tools that flag anomalies such as high-risk sourcing regions, labour migration patterns, or subcontracting density. Boards can then interrogate these insights as part of their quarterly reviews. A practical illustration is Nestlé’s use of blockchain technology to trace cocoa and coffee origins. By enabling real-time verification of supplier practices, the board receives quantifiable evidence of ethical sourcing, not just assurances.

Forward-looking boards understand that modern slavery prevention is not only about compliance, but also about operational resilience and brand trust. Some companies now tie executive remuneration to measurable targets, such as completing supplier audits, reducing reliance on temporary labour, or achieving worker welfare certifications. If we look at Tesco’s 2024 human rights strategy, we can see that it explicitly connects modern slavery prevention to its core sustainability and procurement frameworks. Its board receives integrated ESG scorecards that show supplier risk trends alongside financial and operational metrics (Tesco PLC Annual Report, 2024).

Finally, and I think most importantly, the best boards cultivate informed curiosity. They don’t assume expertise; they invest in it. Some organisations now provide annual board training specifically on modern slavery by NGOs or independent experts. The Independent Anti-Slavery Commissioner has repeatedly urged boards to ‘’ask better questions and listen carefully to answers’’ (IASC, 2024). In short: when education becomes an expectation rather than checkbox, boards gain not just knowledge they gain judgement.

I have learned that good governance is what transforms policy into action. Good governance does not end with a statement or a report; it lives in decisions, contracts and the culture of the organisation. Thus, as we mark Anti-Slavery Day, I see it as a reminder to all of us governance that our responsibility does not end with compliance.

Boglarka is a chartered governance professional (FCG) and Doctoral Researcher in Corporate Governance and Business Ethics.

• UK Home Office (2025). Transparency in Supply Chains: A Practical Guide. 
• Hope for Justice (2025). Number of Potential Modern Slavery Victims Continues to Rise.
• International Labour Organization (2024). 50 Million People Worldwide in Modern Slavery. 
• The Guardian (2024). Sexual Exploitation Drives Profits from Forced Labour.
• Walk Free (2025). Modern Slavery Laws in the UK and Australia Are Failing and Need Urgent Reform.