All commercial organisations carrying on business in the UK with turnover of £36m or more will from October 2015 have to complete a slavery and human trafficking statement for each financial year. The Modern Slavery Act consolidates offences relating to trafficking and slavery (both in the UK and overseas). It includes a provision for large businesses to publicly state each year the actions they are taking to ensure their supply chains are slavery free.
The ‘slavery and human trafficking statement’ must include either an account of:
- The steps being taken by the organisation during the financial year to ensure that slavery and human trafficking is not taking place in any part of its business or its supply chains, including:
- Information about the organisation's structure, business and its supply chains.
- Its policies in relation to slavery and human trafficking.
- Its due diligence processes in relation to slavery and human trafficking in its business and supply chains.
- The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk.
- Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate.
- The training about slavery and human trafficking available to its staff.
- That the organisation is not taking any such steps (although this is permitted under the Act, it is likely to have public relations repercussions).
The statement must be formally approved by the organisation, for example, through its board of directors and must be published on its website. Failure to do so may lead to enforcement proceedings being taken by the Secretary of State by way of civil proceedings in the High Court.
Statutory guidance is still awaited. However, we would advise that organisation this applies to start to work on the statement to ensure compliance and are happy to assist with this.