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.
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.”
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.