New Modern Slavery Regulations require companies to act

Last year, the UK Government was one of the first to address the issue of modern slavery through legislation. The Global Slavery Index estimates that 35.8 million men, women and children around the world are trapped in modern slavery today.

The legislation will require action by ‘commercial organisations’ that have a global turnover of more than £36m. Specifically, they will have to publish a statement setting out what steps they have taken to ensure that no slavery or human trafficking exists in their supply chains.

The reason we are mentioning it now is that these requirements kick in at all year ends starting from 31 March 2016.

What is required?
The ‘transparency in supply chains’ provisions requires the preparation of a slavery and human trafficking statement for each financial year. This is a statement that either:

• sets out the steps that the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business; or
• states that the organisation has taken no such steps.

Clearly, the latter of these two option is not very attractive!
The statement may include information on the organisation’s:

• structure, business and supply chains
• policies in relation to slavery and human trafficking
• due diligence processes in relation to slavery and human trafficking in its business and supply chains
• the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps that it has taken to assess and manage that risk
• its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate, and
• training about slavery and human trafficking available to its staff.

The statement must be approved at the highest level of an organisation, and it must be published on its website and include a link to the statement in a prominent place on the homepage. The government’s guidance says that they expect organisations to publish their statements as soon as reasonably practicable after the end of each financial year in which they are producing the statement and, in practice, within six months of the organisation’s financial year end.
Something to consider is that these requirements will need to be reflected in existing company policies and practices already in place e.g. disciplinary policies, supplier contract arrangements etc.

Read the UK Government guidance issued under section 54(9) of the Modern Slavery Act 2015.

For more information and help in complying with the regulations, please contact Ed Hussey in the HR Consulting team.