London Partner Lucy Blake was featured in Forward Law Review, where she commented on the UK government's proposed overhaul of the Modern Slavery Act 2015's corporate reporting regime - the biggest changes to section 54 since it was introduced. Lucy's insights highlight the shift toward mandatory disclosure, board-level accountability, and financial penalties for organisations and public authorities that fail to comply.
Lucy offered her observations on what the reforms mean for businesses:
"This is the first time Section 54 has carried a financial consequence, and that alone is likely to focus minds in a way a purely reputational obligation never quite did. A fine calculated as a percentage of turnover means the largest companies carry the largest exposure – a structure that puts real pressure on the biggest businesses to get this right."
Lucy also commented on the mandatory reporting requirements and the wider compliance landscape businesses are now navigating:
"Prescribing the content of a statement removes a lot of the judgment calls companies have previously been able to make about what to include. Companies are no longer facing a single point of pressure – they're operating in a converging storm of scrutiny: courts, investors, parliamentary select committees, the press, and now a regulator with fining powers. This isn't happening in isolation. The US and Canada already ban the import of goods linked to forced labour, the EU's own ban follows in 2027, and the UK is now considering the same step. Financial penalties may be the first tool out of the box, but they're unlikely to be the last."
Lucy Blake helps clients prevent, investigate, respond to, and recover from all manner of wrongdoing, including non-financial misconduct and "ESG" risks arising from human rights impacts in companies' supply chains. Lucy is a Co-Chair of the firm's Human Rights and Global Strategy Practice, and frequently advises on multi-jurisdictional issues involving conflicts of laws and divergent legal, commercial, reputational, and political risks.
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