Modern Slavery and Human Trafficking Statement
Every commercial organisation turning over more than £36m per annum must publish a slavery and human trafficking statement. This requirement came into effect for financial years ending on or after 31 March 2016. The statement must be published as soon as possible after the end of the financial year. There must be a prominent link to the statement on the Home page of the website. If there is no company website, a copy of the statement should be provided in hard copy, to anyone making a written request, within 30 days of the request.
So what needs to be in the statement? According to Part 6, Section 54 of the Modern Slavery Act 2015 you should consider including the following information:
- your organisational structure, the business you are in, your supply chain;
- your policies in relation to slavery and human trafficking;
- the due diligence processes you have in relation to slavery and human trafficking in your business and supply chains;
- the parts of your business and supply chain where there is risk of slavery and human trafficking, and the steps you take to assess and manage the risk;
- the key performance indicators that you use to measure the effectiveness of your monitoring;
- the training that you have in place regarding slavery and human trafficking.
The statement must be updated at the end of each financial year, and the Board, or the most senior Director must sign it off.
Definition of a commercial organisation
Any business (or part of a business), irrespective of where they are incorporated, that supplies goods or services in the UK and has an annual global turnover of £36m or more. This includes subsidiaries of world-wide organisations.
Any overseas subsidiaries of UK companies that produce goods or services sold in the UK are also subject to this regulation.
What does this mean for small and medium sized firms?
Whilst the SME does not need to declare any information regarding slavery and human trafficking, they could be subject to the regulations as a supplier to companies who do need to make a declaration. Those required to comply must show how they ensure that their supply chain does not engage in slavery or human trafficking. This means SMEs will need to consider what policies they may need to put in place.
Large organisations required to provide a modern slavery and human trafficking statement must undertake due diligence on their supply chains. They must actively find out who their suppliers employ. Many are including anti-slavery and human trafficking clauses in their supply contracts. Tenders may also require confirmation by the prospective supplier that they comply with their policy of ante-slavery before being considered as a supplier.
The government have issued guidelines: Transparency in Supply Chains etc. A practical guide
If you would like TimelessTime to help you develop your own statement please get in touch.