A/HRC/30/35 the Modern Slavery Act 28 can be enforced in civil proceedings undertaken by the authorities. Under the Act, company disclosures must be signed by a company director, creating clear accountability. Regulations are currently being prepared to operationalize the provisions for transparency, based on consultations. In some of the submissions for the consultations, it was suggested that a threshold be introduced that would bring even small companies within the ambit of the Act, which would require companies to reveal business relationships in the lower tiers of their supply chains and set clear criteria for disclosures in their reports; it was also suggested that reports be featured on a government website. The Act has, however, received criticism for creating a loophole that allows United Kingdombased companies to effectively “hide” their supply chains if the goods produced do not enter the United Kingdom.29 32. In the context of transparency, the most often cited legislation is the California Transparency in Supply Chains Act of 2010,30 which came into effect on 1 January 2012. Under the Act, all retailers and manufacturers with annual global revenues of over US$100 million doing business in California, whether or not they have their headquarters there, are required to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains for tangible goods offered for sale. While an important development, the law is judged to be insufficient because it only requires companies to report on what, if anything, they are doing to address contemporary forms of slavery, using five specific categories: verification, auditing, certification, internal accountability and training, and no specific preventive actions need to be taken nor does it call to improve conditions for those vulnerable to abuse in the supply chain. 31 33. In 2014, the draft Business Supply Chain Transparency on Trafficking and Slavery Act of 201432 was introduced into the United States Congress. The Act, not yet adopted, contains, inter alia, reporting requirements for businesses relating to the disclosure of conditions amounting to forced labour, slavery, human trafficking and the worst forms of child labour in supply chains. At the time of writing the present report, a draft law on business human rights due diligence in supply chains was pending before the Senate in France,33 after having been adopted by the National Assembly in the first reading in March 2015. 34. The Brazilian Ministry of Labour maintains a record of people and corporations found to be using slave labour, which has been termed the “dirty list”, established by ministerial decree of 2003. The database was used by public and private companies that applied commercial and financial sanctions. The list grew to include 52 employers of slave labourers in 2003 to 609 as of July 2014. However, in December 2014, the Supreme Court granted an injunction to an association of construction companies, suspending the “dirty list”. To date, attorneys from the Federal Government have not been able to re-establish the database. Another challenge to the list was launched following the Labour Prosecutor’s 28 29 30 31 32 33 10 Available at www.legislation.gov.uk/ukpga/2015/30/pdfs/ukpga_20150030_en.pdf. See Anti-Slavery International, www.antislavery.org/english/press_and_news/news_and_press_releases_2009/analysis_of_modern_sl avery_act.aspx. Available at www.state.gov/documents/organization/164934.pdf. See Verité, “Compliance is Not Enough: best practices in responding to the California Transparency in Supply Chains Act” (2011) (www.verite.org/sites/default/files/VTE_WhitePaper_California_Bill657FINAL5.pdf), and the Alliance to End Slavery and Trafficking, “Beyond SB 657: How Businesses Can Meet and Exceed California’s Requirement to Prevent Forced Labour in Supply Chains” (2013) (www.genderprinciples.org/resource_files/ATEST_Report_Beyond_SB657_final.pdf). Available at https://www.congress.gov/113/bills/hr4842/BILLS-113hr4842ih.pdf. Text No. 376 (2014–2015), available at www.senat.fr/leg/ppl14-376.pdf.