It is now over a year since the first organisations were required to start producing their slavery and human trafficking statements in compliance with section 54 of the Modern Slavery Act 2015, making it possible to assess and compare the large number of statements already published. Continue reading


I started in the role of Chief Privacy Officer role at Pearson very recently, though I have been in the Legal team for eighteen years. I have been blessed with a wealth of resources at my disposal: a central Data Privacy Office team, policies for each area of the business, an incident response toolkit, an established privacy impact assessment process, memberships of various expert bodies and access to training and knowledge resources. I realise that probably makes me very lucky amongst many of you.
But even with the backing of good infrastructure, making best use of resources is key. So what have been the next steps?

Giving your employees access to the right speak up channels (or ‘intake’ channels) is a critical part of any whistleblowing programme.
But what are the most commonly used channels, what are their pros and cons, and which are likely to be the most effective within your organisation?

I attended Practical Law’s GC Leadership Summit last week. This year’s central theme was innovation which set the scene for some interesting discussions on corporate governance, the changing role of the general counsel and approaching the GDPR and cyber challenges, amongst other things. Here’s a whistle-stop tour of some of the key messages. Continue reading

Brexit: June round-up
The key developments this month were the formal start of Brexit negotiations and the publication of several Brexit-related Bills in the 2017 Queen’s Speech.

PSC legislation issued at the eleventh hour
From Monday, a significant number of entities that were previously outside the scope for the PSC regime have been brought within it with a very narrow time frame to create their registers and provide details to Companies House.
The Information about People with Significant Control (Amendment) Regulations 2017 were published on 23 June and, as expected, took effect from 26 June 2017.

Practical Law has published a report on the results of the survey I previously wrote about which sought to examine how in-house lawyers, and the organisations they work in, were approaching Brexit.
The report can be accessed here and is also available in PDF format.

What’s on the agenda for in-house lawyers in July 2017?
Key items on the agenda for businesses this month include digesting the implications of the new Bills and proposals announced in the Queen’s Speech, reviewing a report on directors’ remuneration voting trends and continuing preparations for GDPR.

I wouldn’t ordinarily wish to be responsible for lawyers giving up their weekends. However, I hope I’ll be forgiven if this notice helps you out of a hole.
The final version of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 were published today and the deadline for implementation is this coming Monday (26 June 2017).

A new piece of French legislation came into force on 1st June, “The Law on Transparency, the fight against corruption and the modernisation of economic life” – also known as ‘Loi Sapin II’. With this new law comes lengthy obligations for those businesses with a presence in France.