The Modern Slavery Act 2015 is new legislation introduced in the UK with the intention of combatting slavery and human trafficking.  Continuing the trend for legislation to have extra-territorial reach, as illustrated by the UK Bribery Act, it can apply to entities based outside of the UK.

Of particular importance to businesses is Section 54. This contains a requirement for certain businesses to state annually and publicly the steps they have taken to ensure that their business and supply chains are free from human trafficking and slavery (a “Section 54 Statement“).

Concluding a year-long review, UK regulators issued the final report of the Fair and Effective Markets Review Committee last week, making a number of recommendations intended to restore confidence in the trading markets for fixed income, currency and commodities (“FICC”) in the wake of past misconduct.

The report noted the substantial fines that have been levied in recent years in connection with the attempted manipulation of LIBOR, foreign currency and other trading benchmarks and market prices, misrepresentations to investors and collusion.  Indeed, since 2012 authorities in multiple jurisdictions have imposed criminal and regulatory penalties aggregating more than $10 billion related to this conduct.  In June 2014, the Chancellor of the Exchequer, together with the Governor of the Bank of England, launched the Review to recommend changes in regulatory policies in the relevant markets.