Whilst “slavery” seems an old-fashioned word, don’t be deceived. Read on to find out what your obligations may be.
Section 54 of the Modern Slavery Act 2015 requires large commercial organisations to publically state the actions they have taken ensure that their business and supply chains are slavery-free.
Although the Modern Slavery Act 2015 is now in force it does give employers some breathing space and the obligation to provide public statements doesn’t kick in until after 31 March 2015.
Does the Modern Slavery Act apply to me?
If you are a commercial organisation, you must produce an anti-slavery statement if:
- You are a body corporate or partnership carrying out business in the UK;
- You supply goods or services; and
- You have a turnover of £36million.
What must the anti-slavery statement say?
If you are required to produce an anti-slavery statement then it must set out the actions your organisation has taken to ensure that your business and supply chains are free from slavery. That is the only obligation as such.
However, we have had some useful guidance and the statement may include (and in my advice should include) information about your:
- Structure, business and supply chains.
- Policies on slavery and human trafficking.
- Due diligence processes on slavery and human trafficking in its business and supply chains.
- 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 that risk.
- Effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against appropriate performance indicators.
- Staff training on slavery and human trafficking.
What does this mean for me?
Slavery is not something that most businesses expressly deal with within their business, nor is it common to have policies and procedures on this. That means therefore that there are q few action points if you are going to have to provide a statement.
Working out when you need to publish your statement
Your first statement should refer to your financial year ending after 31 March 2016.
Identifying who should sign off the statement
In the case of a company, the statement must be approved by the board and signed by a director.