We recently wrote about the implications of the Modern Slavery Act for employers.
As a reminder, the Modern Slavery Act states that organisations with an annual turnover of over £36 million need to produce a slavery and human trafficking statement. Such a statement is required for each financial year ending on or after 31 March 2016. It should detail the steps taken to combat slavery in all parts of the business and supply chain.
The legislation does not specify a time-frame in which the statements have to be produced. However, government guidance suggests that publication should be within six months of the end of a company’s financial year. For organisations with a financial year that ended on 31 December 2016, the deadline for them to publish their first slavery and human trafficking statement would have been 30 June 2017.
Modern Slavery Act: slavery and human trafficking statement – what to include
Statements may include information on a company’s supply chains; the due diligence carried out on suppliers; any staff training initiatives that have been implemented; details of relevant policies that have been introduced; and details of how effective the measures have been in preventing slavery in the business and its supply chains. Statements need to be signed by a director and published in a prominent place on the company’s website, or be made available within 30 days of a written request.
Modern Slavery Act for Employers: worth noting
There is no legal obligation for an organisation to take any measures to prevent slavery taking place and any statement produced can simply state that no steps have been taken. However, given such information will be in the public domain, this approach is likely to result in loss of reputation.
Similarly, if a company refuses to produce a statement, only the Secretary of State has the power to apply to the courts for an order to oblige the company to do so. However, this is likely to result in negative publicity and, again, damage the company’s reputation.
If your organisation meets the criteria required to produce a statement under the Modern Slavery Act and you have not yet produced your slavery and human trafficking statement, you should be taking steps to publish this as soon as possible.
If we can support you with this process, please don’t hesitate to contact us on 01271 859 267.
