Modern Slavery- what are your obligations?

Depending on the size of your organisation, you may have an obligation to report on Modern Slavery.

 

If you are a commercial organisation with an annual turnover of £36 million or more, you will have to publish a slavery and human trafficking statement every year under section 54 of the Modern Slavery Act 2015 (“the 2015 Act”).

 

This statement should set out the steps an organisation has taken in the last financial year to ensure modern slavery and human trafficking is not taking place in the business or related supply chains. If no steps have been taken, then the statement must say this.

 

What should be included in the statement?

  • The organisation’s structure, business and supplychains​
  • The organisation’s policies on slavery and human trafficking​
  • The due diligence processes the organisation has undertakenwith regard to the risk of slavery and human trafficking within the business and supply chains​
  • The parts of the business and supply chains wherethere is a risk of slavery and human trafficking​
  • How the organisation measures that slavery and human traffickinghas not taken /is not taking place in the business or supply chains​
  • Staff training.​

 

The statement must be published on the organisation’s website with a link to the statement in a prominent place on that website’s homepage (an organisation that does not have a website must provide a copy of the statement on request within 30 days).

 

Failure to provide the statement, the Secretary of State can apply for an injunction to force compliance. If an organisation still refuses to comply they will be deemed to be in contempt of a court order, which is punishable by an unlimited fine.

 

If your organisation does not fall into the criteria, you are not under obligation to report on Modern Slavery. However, your suppliers or future clients who meet the criteria may have to ensure that their business and supply chain does not involve slavery or human trafficking, therefore you may have to confirm to them that your business is free from this. To do so, you may for example provide a statement that states you are committed to ensuring Modern Slavery does not exist in the organisation, should you be asked.

 

In order to combat Modern Slavery further, you could develop an ‘Employing People from Abroad Policy’ which sets out your commitment to a diverse workforce, recruitment process, training and ensure that eligibility to work in the UK checks are carried out and continuously monitored.

 

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