What many businesses may not realise is that they could have a responsibility under section 54 of the recently-enacted UK Modern Slavery Act 2015 to produce a slavery and human trafficking statement each financial year, and that this needs to be hosted on the homepage of a business’s website. The statement needs to state clearly the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.
This currently only applies to businesses with an annual turnover of £36 million or more (whether that is derived in the UK or elsewhere) and while the associated risks with non-compliance are purely reputational at this stage, the UK government does have the right to compel an organisation to issue a statement through an injunction.
Surprisingly, these new requirements have attracted remarkably little debate or publicity. Taking into account the fact that the new law impacts many global businesses that may only have a small UK subsidiary, as well as UK businesses with a modest turnover, it’s safe to assume that many affected businesses may be unaware of their new obligations. The impact of this change is imminent as businesses with a year-end of 31 March 2016 will be the first required to publish a statement under the new rules.
Sophie White, Employment Lawyer and Partner at Abbiss Cadres commented: “While some businesses seem to be completely unaware of the new requirements, there are also other businesses that are producing statements that simply do not meet the statutory requirements, or address fundamental issues such as what policies and due diligence processes the organisation has in place to ensure slavery and human trafficking isn’t happening.”
“Our recommendation is to use the modern day slavery statement as an opportunity to show both your employees and your customers how committed you are to fighting this battle. Invest in seeking the support and guidance not only to draft your statement, review and/or amend current policies but also to think about providing training to employees as part of a much wider corporate social responsibility plan.”
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