Section 54 of the Modern Slavery Act 2015 requires that certain businesses have a statutory obligation to produce a slavery and trafficking statement for each financial year. Businesses required to do this:
- are a commercial organisation in any sector;
- supply goods or services;
- are a business or part of a business in the UK; and
- have a turnover of £36m or more.
The statement must set out what steps the organisation has taken during the financial year to ensure that modern slavery is not occurring internally and throughout their supply chains. This means smaller businesses may be impacted if they are part of a larger organisation’s supply chain.
The statutory guidance that has been issued is quite broad and does not provide a detailed road map for organisations to follow. Therefore some businesses are asking their supply chains for information about relevant policies and others are asking their supply chain to complete supply chain audit questionnaires.
Avoid taking the risk
Understanding the Act and its requirements is a good first step for all business, regardless of whether your turnover is £36m or more. This will be complex at first, so make sure you take appropriate guidance and give yourself sufficient time to undertake the necessary activities. Include those who have a part to play in the implementation of compliance and those that could be impacted by changes to procedures.
You may find that your policies will need to be reviewed and rewritten with fresh eyes and you may want to adopt different or enhanced internal procedures. The execution of these should have greater importance and therefore will impact on how you manage recruitment, induction, appraisal and performance.
At RSM we have a wealth of experience in assisting organisations to investigate, assess particular risks and develop policies and processes that are aligned to their business and we would be happy to discuss this with you.
For more information please get in touch with Steve Sweetlove, or your usual RSM contact.