If you are a commercial organisation supplying goods or services and have a minimum total turnover of £36 million per year, then you are required to produce a Slavery and Human Trafficking Statement. You will need to do this for each financial year that your turnover is above the prescribed amount.
The current transitional provisions state that the requirement only applies in respect of financial years ending on or after 31 March 2016.
Your statement should set out what steps have been taken during the financial year to ensure that modern slavery is not occurring in your supply chains as well as your organisation.
Organisations are required to be transparent about what is happening within their business. This means even if an organisation has taken no steps to ensure slavery and human trafficking is not taking place, they must still publish a statement stating this to be the case.
Even if your organisation pursues primarily charitable or educational aims or purely public functions it doesn’t matter. You can still be liable if engaging in commercial activities and have a total turnover of £36m - irrespective of the purpose for which profits are made.
The Modern Slavery Act statement must be approved and signed by an appropriate senior person in the business, published on your website and include a link in a prominent place on the homepage. There is no prescribed time limit in which to make the statement.
The guidance suggests it should be published as soon as possible after the financial year end to which it relates, to ensure it is timely and relevant. You are encouraged to make the report within six months of the business’ financial year end to which the statement concerns.
As a guide it is suggested the statement should cover topics such as management structure, training, policies, risks, due diligence and key performance indicators. You may also consider including an anti-slavery policy within your employee handbook.
Please contact your designated consultant should you wish to discuss this further or contact Jelf Risk Management on 0345 040 0002 to discuss our employment law services.
Source: Section 54 Modern Slavery Act 2015, The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, Home Office Guidance; Transparency in Supply Chains etc. A practical guide.
Print 
PDF