Time to Comply: the Modern Slavery Act 2015
SECTION 54 OF THE UK MODERN SLAVERY ACT 2015 REQUIRES COMMERCIAL ORGANISATIONS WHICH SUPPLIES GOODS OR SERVICES AND CARRIES ON A BUSINESS IN THE UK WITH A TURNOVER THRESHOLD OF £36mn TO PUBLISH AN ANNUAL MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT.
THIS STATEMENT MUST SET OUT THE STEPS TAKEN IN THE FINANCIAL YEAR TO IDENTIFY AND EXCLUDE MODERN SLAVERY FROM THEIR OWN BUSINESSES AND SUPPLY CHAINS.
1. What is modern slavery?
While the definition of modern slavery can vary, it broadly refers to slavery, human trafficking, forced labour, debt bondage and exploitation of children.
Modern slavery is hidden crime found in many industries. It can impact most supply chains from food to clothing and merchandising, facilities management services right through to electronics.
Nearly every country in the world has committed to eradicate modern slavery through policy and legislation but few have enacted legislation to enforce the private sector to identify and address human rights risks.
In the UK, The Modern Slavery Act 2015 requires business to produce an annual statement outlining what measures have been taken to ensure no modern slavery exists in the supply chains or own operations. It also requires the need to communicate to consumers and stakeholders on the efforts being made to end human rights abuse.
It is hoped this transparency measure will result in increased competition, collaboration and ultimately drive up standards.
2. Which businesses are affected?
Businesses with a turnover of £36mn or above and that carry out business (provision of goods and services) in the UK. The legislation will affect over 12,000 businesses in the UK.
3. What is required from business?
Businesses must publish an annual Modern Slavery Statement disclosing:
> The steps taken to ensure slavery and human trafficking is not taking place through the operation of their business and their supply chains
> A declaration that no steps have been taken.
4. What needs to be disclosed?
An organisation’s slavery and human trafficking statement for a financial year may include information about:
> An organisation’s structure, its business and its supply chains
> Company policies that relate to slavery and human trafficking (e.g. ethical supply policy, human resources policy)
> Due diligence processes in relation to slavery or human trafficking in operations and supply chain (e.g. supplier audits)
> The parts of the business and supply chains where there is a risk of slavery and human trafficking taking place, and the measures taken to assess and manage that risk
> An assessment of the effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains against a set of key performance indicators as it considers appropriate.
> Details of any training for key staff and key staff within supplier organisations.
5. Who signs it off?
Sign off and approval of the statement should be by the board, members or partners depending on company structure.
6. Where should the statement be published?
If the organisation has a website, it must publish the Modern Slavery Statement on that website and Include a link to the statement in a prominent place on that website’s homepage.
7. When should the statement be published?
The statement should be published within a reasonable period (perhaps six months) of a company’s Financial Year End (after 31 March 2016).
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