The Modern Slavery Act 2015 (Act) was introduced last year to tackle modern slavery and human trafficking, by encouraging large businesses to scrutinise every stage of their supply chains and ensure they are slavery-free.
Will the Act apply to your charity?
The Act affects commercial organisations that supply goods or services and have a minimum total turnover of £36 million. This figure is for global turnover, not just UK turnover. There are no particular sectors that are excluded from the effect of the Act, and the Home Office has confirmed that large charities will be caught by the Act’s requirements.
What do you need to do?
Large charities that are subject to the Act will need to publish an annual "slavery and human trafficking statement" for each financial year ending on or after 31 March 2016. The statement should either:
- set out steps the charity has taken to ensure that there is no slavery in its supply chain; or
- state that the charity has taken no such steps.
It is highly unlikely that businesses subject to this new duty will take option 2 due to potential reputational damage, and this would arguably be all the more the case for charities.
The statement should be in plain English and should be displayed on your charity's website; there must be a prominent link to the statement from your home page.
Businesses have discretion over how much detail to include in the statement. It could include information on the structure of your organisation, any relevant policies you have in place, relevant due diligence processes, a risk assessment on parts of the supply chain that are likely to be affected, training for staff and so on.
The statement must be approved by the charity's board and signed by a trustee.
Our July briefing on the Modern Slavery Act 2015 – Transparency in Supply Chains provides further background and detail on the effect of the Act.