In 2015, the Modern Slavery Act introduced three new criminal offences:
- Slavery or servitude;
- Forced or compulsory labour; and
- Human trafficking and committing an offence with the intent to commit human trafficking (including aiding, abetting, counselling or procuring human trafficking).
In addition to avoiding violation of any of the offences, commercial organisations with a total annual turnover of more than £36m are required to prepare and publish an annual slavery and human trafficking statement.
It is each organisation’s responsibility to determine whether the legislation applies to them and it is important to take into consideration that the ‘total annual turnover’ is inclusive of the entire organisation, including any subsidiary undertakings (even if they operate wholly outside of the UK).
Although there is no set format for the annual slavery and human trafficking statements, the Home Office’s guidance recommends that you cover your:
- Organisation structure and supply chains;
- Policies in relation to slavery and human trafficking;
- Due diligence processes;
- Risk assessment and management;
- Key performance indicators to measure the effectiveness of preventative steps being taken; and
- Provision of staff training and awareness of modern slavery and trafficking.
Your statement should also demonstrate that you are acting transparently and disclosing information about any modern slavery risks that you have identified and what actions you have taken in response to them. It is also important to emphasise the steps that you are taking to address any possible risks and that you are prioritising your actions to achieve maximum impact.