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Last week the cotton harvests started in Uzbekistan and Turkmenistan. It is expected that as in previous years, the crop will be picked by state sponsored forced labour on a mass scale. Events like these test the preparedness of British businesses for their new duty to report on their efforts to eradicate slavery from their supply chains.

Under the transparency in supply chains provision in the Modern Slavery Act, UK registered businesses with annual turnover over £36 million will be required to publish a statement indicating what they are doing to address forced labour in their supply chains.

To report is all that is required. Parts of the government have been keen to point out to businesses just how little will be required of them and that its primary intention is not to overburden businesses with reporting.

No formal monitoring or review mechanism is attached to the transparency provision, nor has the government agreed to create a central government repository for the reports, as it believes that the accuracy of the company reports is best assessed by civil society and consumers.

There are two fundamental flaws in this approach:  First, it is not the responsibility of the populus to police the implementation of a law. Second, even if this approach were appropriate, much business is not consumer facing and so there are even fewer possibilities for ethically engaged consumers to pressurise for change. For example, commodity traders or suppliers of components for diverse retail goods may act with considerable impunity irrespective of how egregious the human rights abuses in their supply chains may be.

Cotton is one such commodity through which traders - some of whom are UK based – may play a part in perpetuating global slavery. The fifth and seventh largest cotton exporting countries in the world are Uzbekistan and Turkmenistan. Both countries have historically used forced labour to produce and harvest cotton.

Unlike in other countries in which there is a considerable risk of forced labour in the supply chain, such as Bangladesh or India, it is not unscrupulous businessmen behind forced labour in Uzbekistan and Turkmenistan. The governments of these countries have systematically coerced their own citizens to cultivate and pick cotton under threat of punishment.

The vast profits from the sale of cotton benefit a small elite rather than the people of the country. Forced labour of their own citizens has been accompanied with sustained campaigns to silence anyone who tries to document forced labour and publicise the abuses abroad.

Last year, millions of teachers, doctors and nurses were forced into the cotton fields in Uzbekistan, leaving essential services decimated. This year we are unlikely to see much change. Nurses in one district were required by the hospital management to sign documents stating that they will voluntarily agree to go to the cotton harvest. At the same time, they had to sign an undated resignation letter that would be used if they fail to turn up for the harvest.

The Uzbek government buys all the cotton at a price it sets and sells it on international markets with huge profits. While most Uzbek cotton is sold to China and Bangladesh, some European traders, such as the Liverpool based Cargill Cotton, which confirms on its website that it sources from Central Asia, continue to purchase cotton that has a huge risk of being produced through slavery. 

Even international businesses that do not trade in cotton or cotton products, but have business operations in Uzbekistan, are also at risk of contributing to and profiting from forced labour. Workers at General Motors Uzbekistan have reported that for several years, their company has sent them to the cotton harvest. Scandinavian telecommunications companies Teliasonera and Telenor reported that they sponsored the cotton harvest in Uzbekistan. Campaigners understand that the requirement to contribute financially to the cotton harvest applies to all multinational companies that operate in Uzbekistan.

The Modern Slavery Act, for all its flaws, can still have a very positive effect on how British business operates. But to achieve that, the government needs to step up its game for the implementation of the Act and change how it communicates with British businesses about the risks of slavery.

The soon-to-be published guidance for businesses on the implementation of the transparency provision should not only encourage good practice in eradicating slavery in business operations, but also direct businesses to independent sources of information about places and commodities at risk. The government should also amend the Overseas Business Risk Information to include information about forced labour in Turkmenistan and put Uzbekistan on the list.

But most importantly, the British government ought to clearly communicate to the governments of Uzbekistan and Turkmenistan that they need to stop the enslavement of their own citizens, rather than only promote trading with both countries.

It remains to be seen if the British government grasps these opportunities, or satisfies itself with polite words that compel no change in business practices that keep millions across the world enslaved.