Modern Slavery Act 2015

If the company has an excess of £36 million turn over in the UK then it will need to comply to the requirements of the Modern Slavery Act 2015. This entails publishing a slavery and human trafficking statement on the company’s website for each financial year. The statement should cover the steps the company has taken during the financial year to ensure slavery and human trafficking is not taking place in the company or in the supply chain. The steps you have taken should be disclosed. However if you do publish a statement stating the company has taken no steps then this may give rise to a risk of reputation.  

The act itself does not set a deadline for when the statement should be published but companies should do so within 6 months from the end of the financial year. Most companies will publish at the same time at their annual report and accounts.

The statement needs to include:
- The company’s structure with a summary of the procedures and the supply chains
- Any relevant policies relevant to slavery and human trafficking
- Any due diligence processes relevant to slavery and human trafficking in the company and supply chains.
- The areas of risk of slavery and human trafficking to the company and supply chains and any steps taken to assess and manage the risk.
- How effective is the company’s approach to ensure slavery and human trafficking is not taking place in the company or supply chains
- Training in relation to slavery and human trafficking

If a company does not comply then the Secretary of State could force you to disclose the statement via an injunction. Although there is likely to be pressure from stakeholders which will encourage compliance.

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Authors: Roxanne Bradley

Published: 14 Nov 2018

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