“Firstly, government restrictions are triggering a global recession. This will push more people into poverty and vulnerable circumstances, creating the conditions in which modern slavery thrives. It also makes it more difficult to undertake the essential work of inspecting sites and checking the wellbeing of vulnerable workers,” he outlined.

“At the same time, we know that global cooperation is needed to respond effectively to the problem of modern slavery. Unfortunately, the pandemic has closed borders and caused many nations to look inwards. There has also been a scramble by governments to obtain essential medical supplies and secure supply chains.

“Among all this urgency, it is likely that there has been less attention paid to how the goods are being sourced.”

In the wake of the economic uncertainty created by the pandemic, modern slavery may have “slipped down the corporate priority list” for some businesses and organisations, Mr Milnes mused.

“Some companies are facing a battle for financial survival. Others face the enormous operational challenges of responding to extraordinary levels of consumer demand. There are challenges at a practical level too,” he said.

“With staff working from home, it has become more difficult to coordinate all the day-to-day work needed to comply effectively with modern slavery reporting obligations.”

The government, for its part, has recognised these challenges, Mr Milnes observed.

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“For the first companies to report, the reporting deadline has been extended by three months, although it is important to note that it is not the duration of the reporting period itself that has been extended. The government has also issued guidance to companies on how to account for COVID-19 in their modern slavery statement,” he said.

When asked what steps corporate counsel can take to address the current issues and challenges, Mr Milnes said that many companies have previously issued statements to say they are committed to tackling the problem of modern slavery in their supply chains, and that such commitment is now being put to the test.

“Corporate counsel are in an ideal position to provide the ethical leadership and advocacy now needed to keep modern slavery on the corporate agenda,” he advised.

“There are also plenty of opportunities for corporate counsel to get involved and contribute – whether that is providing training, raising awareness across the organisation, recommending suitable contractual protections, advising on internal processes or other similar efforts.”

The pandemic, Mr Milnes concluded, has focused the whole world on supply chains and risk.

“Organisations realise that rebounding successfully from COVID-19 will mean having to know more about their supply chains, and how and where products are sourced. Consumers will increasingly demand it,” he said.

“Corporate counsel will play an important role in supporting these efforts – so that future supply chains are efficient, resilient and free from modern slavery.”