Large organisations in the UK will be required to publish a ‘slavery and human trafficking statement’ from as early as October 2015. The Government has indicated that it will be producing statutory guidance to help businesses to comply with this requirement including guidance on how businesses can identify modern salary and good practice for due diligence processes.
The requirement, which is being introduced by the supply chain transparency provisions of the Modern Slavery Act 2015, will apply to commercial organisations that supply goods or services with an annual global turnover of at least £36 million. Those covered by the legislation will be required to publish a slavery and human trafficking statement for each financial year, setting out the steps the organisation has taken (if any) to ensure that no slavery exists in its business or its supply chains. The statement must be published on the organisation’s website.
Organisations are likely to have to take steps such as mapping supply chains, putting clear procurement policies in place, ensuring there are adequate contractual protections in place, undertaking site inspections, delivering consistent messaging throughout the supply chain and training employees and local suppliers. Companies should review existing compliance policies, contractual provisions and supply chain relationships to identify gaps and risks prior to the reporting requirement coming into effect.
Failure to comply with this new requirement may result in civil proceedings in the High Court for an injunction requiring the organisation to comply. However, public scrutiny is likely to provide the principal incentive for compliance.
Reference: Part 6, the Modern Slavery Act 2015