From October any large business that operates in the UK will be required to publish a ‘modern slavery statement’.
The statement must outline the steps that the business has taken to ensure that neither slavery nor human trafficking is taking place within their company. This also extends to any supply chains, whether UK-based or otherwise.
If a business has not taken any steps to prevent slavery or human trafficking then they must make a statement to that effect.
The legislation forms part of Section 54 of the Modern Slavery Act 2015, which came into force last Friday (31st July). Section 54 will apply to all organisations that carry out business in the UK with an annual turnover above a certain threshold. This is regardless of where the company is registered.
The Government has not yet clarified the exact threshold but the figure is expected to be £36 million, including both the turnover of the parent organisation and that of its subsidiaries. The threshold and the first reporting date will be confirmed before October.
Section 54 outlines that the following areas that could be included in the statement:
The organisation’s structure, business and 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
Areas of its business and supply chains where there is a risk of slavery and human trafficking taking place and the steps taken to manage that risk
How effective the business is at ensuring that slavery and human trafficking is not taking place in its business and supply chains, including any measurable performance indicators
Any training about slavery and human trafficking available to its employees
The statement must be approved and signed by a Director and published in a prominent position on the website.
If a qualifying business does not issue a statement then the Secretary of the State has the power to apply for an injunction and force the issue. What the Government is relying on is that the fear of reputational damage will be enough to persuade a business to provide a statement of its own accord.
We will provide further guidance on this as it becomes available.