The government has sought to combat and prevent modern slavery through the introduction of the Modern Slavery Act 2015, which covers the offences of slavery, human trafficking, servitude and forced or compulsory labour.
A key provision of the Modern Slavery Act 2015 requires certain organisations to produce an annual slavery and human trafficking statement that sets out what action has been taken to eradicate it within their business or supply chains.
Who is required to comply?
Any organisation, including those as part of a group structure, will be required to produce a statement if they:
- are a corporate or partnership body, irrespective of where they are incorporated;
- undertake business, or part of a business, in the UK;
- supply goods or services; and
- have an global annual turnover of £36m or more.
Organisations with a 31 March 2016 financial year end will be the first required to publish a statement. Where an organisation meets the criteria above, a statement should be published annually thereafter.
Content of the statement
The Modern Slavery Act 2015 does not dictate what information must be included within the statement. There is, however, a general consensus as to what information would generally be considered good practice to include:
- the organisation’s structure, business and supply chain;
- policies relating to slavery and human trafficking;
- slavery and human trafficking due diligence processes across its business and supply chains;
- the parts of the business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage this risk;
- an assessment of the effectiveness of arrangements to ensure slavery and human trafficking is not taking place, including performance against any relevant performance indicators established; and
- details of training available to staff.
Whilst compliance is mandatory, it is anticipated that the increased transparency resulting from the Act’s reporting requirements will also lead to competitive advantages such as increased investor confidence, brand enhancement and improved customer loyalty.