Large employers will be required by law to publish a modern slavery statement every financial year stating the steps they have taken to prevent slavery, the government confirmed last week.
This provision will be introduced via section 54 of the Modern Slavery Act 2015 and will affect commercial all organisations that supply goods or services in the UK and have a global turnover of £36 million.
DLA Piper employment partner Jonathan Exten-Wright said:
“The legislation will have a broad impact and effect business very quickly. There is an immediate need for businesses to engage on this subject and prepare to publish a modern slavery statement.
“Businesses will need to address how this is integrated into their existing risk management systems, how they undertake due diligence, their supply chain relationships and planning for appropriate director sign off.
“Business should not underestimate just how dramatic this legislation is, not least in terms of their reputation as this will be an iterative process every year.”
The government will produce statutory guidance on how to produce the statement. Failure to comply could result in legal action.
Anne Pritam, employment partner at international law firm Stephenson Harwood LLP, comments on the Modern Slavery Act 2015 explains what slavery commented:
“Further details of the duty and guidance on its scope are still to be published by the government, and there will be transitional provisions for those whose financial year ends shortly after the provisions are introduced. However, organisations carrying on business in the UK with a turnover above the £36 million threshold can start preparing now by doing the following:
1) Appointing an appropriate person to be responsible for compliance;
2) Ensuring that staff, particularly those involved in recruitment, procurement and supply chain management, are aware of the new requirement and are appropriately trained to make the right enquiries of potential suppliers;
3) Reviewing supply contracts to ensure supppliers have appropriate safeguards in place;
4) Considering the introduction of a slavery and human trafficking policy.
“This new obligation is potentially onerous and, while organisations will be entitled simply to say in the Statement that no steps have been taken, this is likely to be unattractive for reputational reasons. Early preparation will be key to full compliance.”
Slavery and human trafficking statement
Section 54 of the Modern Slavery Act 2015 states that the employer’s slavery and human trafficking statement might include information on:
- its structure, business and supply chains;
- its policies in relation to slavery and human trafficking;
- its 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
- the training about slavery and human trafficking available to its staff.