The Modern Slavery Bill also received Royal Assent yesterday. The Act introduces a transparency in supply chains provision that requires all businesses over a certain size to produce a “slavery and human trafficking statement” for each financial year. The statement must disclose steps businesses have taken to ensure their business and supply chains are slavery free, or a statement that no such steps have been taken. The threshold, determining which businesses are within scope, is expected to be based on a minimum turnover of the commercial organisation i.e. group. The requirement will apply to commercial organisations over the threshold, which carry on a business, or part of a business, in the UK. The Home Office is consulting on what size of business this new requirement should apply to and on statutory guidance to accompany the provision.
Macfarlanes’ client note is available here.
Impact – if within scope, businesses will need to consider whether they have adequate procedures in place to ensure slavery and human trafficking is not taking place in any of their supply chains or in any part of their group’s business. It may be prudent for large businesses to consider their procedures now. The transparency in supply chains provision has a provisional implementation date of October 2015.
Background – the Act consolidates the current offences relating to trafficking and slavery. It creates two new civil orders to prevent modern slavery; establishes an Anti-Slavery Commissioner; and makes provision for the protection of modern slavery victims.