Slavery probably isn’t something that most of us would automatically associate with companies in the UK in the twenty-first century.
However, “modern slavery” (which also includes servitude, forced and compulsory labour and human trafficking) remains a very real problem – including within the UK. In 2013, 1,746 cases of slavery were reported in the UK alone and it affects some 29.8 million people worldwide. Provisions set out within the Modern Slavery Act 2015 will require any organisation with an annual turnover of £36m or more, that conducts business in the UK, and that supply goods or services to publish a modern slavery statement each financial year.
The statement must be published in a prominent place on the company’s website as soon as reasonably practicable after the end of the financial year. Organisations without a website must make a copy of the statement available to anyone who submits a written request, within 30 days of receipt of the request.
What does this mean for businesses?
It’s crucial that all businesses affected by the legislation take steps to identify any risk of modern slavery within their supply chains.. For many organisations, any problems may not be easily visible, as they may not be within the organisation itself, or even at the first level of the supply chain, but possibly much further down. The discovery of modern slavery anywhere within their supply chain and any resulting adverse publicity may lead to considerable damage to their reputation, reduced sales, loss of contracts and a fall in any share price.
If you are required to produce a statement, you should appoint a senior member of staff to be responsible for the compliance. You will also need a good understanding of your supply chain, both overseas and in the UK, and to put measures in place to manage any potential risk. Most statements are expected to include information about the organisation’s structure, its supply chain, the steps taken to prevent modern slavery, links to any associated documents (such as a business ethics policy, whistleblowing policy, Code of ethics for suppliers etc), the training provided to relevant staff and the KPIs that will be used to measure how effective your processes are and to track progress.
Note for smaller organisations:
even if your business has an annual turnover of less than £36 million, if you supply to an organisation that does, you may still find that you are affected as your customer will want to demonstrate that it is taking appropriate steps to try to ensure that each component in its supply chain is free of modern slavery.
As this legislation may affect many of our clients, we are running a webinar to explain what it means in practice, and what organisations need to do to prepare and provide this information.
If you would like to attend, please sign up below: