Transitional provisions are running out fast. Organisations with a financial year end from 31 March 2016 must publish their statement within 6 months of that year end. Is your organisation ready?
The Modern Slavery Act 2015 requires commercial organisations, supplying goods or services, with a turnover of £36 million or above to publish an annual statement setting out what they are doing to ensure that there is no modern slavery both in their own organisation and in any of their supply chains. The turnover calculation includes those organisations that are only carrying out part of their business in the UK, as well as including the turnover of foreign subsidiaries, so supply chains can be complex particularly as services are caught as well as goods.
Although the provisions come into force on 29 October 2015, organisations were given some breathing space because transitional provisions provided that organisations with a financial year-end from 29 October up to and including 30 March 2016 are not required to make a slavery and human trafficking statement for the financial year 2015/16.
However organisations with a financial year-end of 31 March 2016 onwards are required to publish a slavery and human trafficking statement for the financial year 2015/16 within 6 months of their financial year. For some, this could be as early as the end of September 2016. Time is ticking to comply.
The race to the top to drive up standards is gathering pace.