Commercial organisations with a UK presence and a global turnover of £36m or above will be required to publish an annual statement of the steps it has taken to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business.
This requirement is set out in s54 of the Modern Slavery Act 2015. The Government has now responded to the consultation on this by further confirming that guidance will be produced and published to coincide with the duty coming into force in October 2015. It has however also stated that transitional provisions will be developed so that statements are not required where a businesses’ financial year end is within close proximity to the date that the duty comes into force.
There will be 5 areas that a company will be expected to cover within this annual statement:
a) A brief description of an organisations’ business model and supply chain relationships;
b) Policies relating to modern slavery, including due diligence and auditing processes implemented;
c) Training available and provided to those in (i) supply chain management and (ii) the rest of the organisation;
d) The principal risks related to slavery and human trafficking including how the organisation evaluates and manages those risks in their organisation and their supply chain; and
e) Relevant key performance indicators (Key performance indicators are measures that will assist the reader of a slavery and human trafficking statement to assess the effectiveness of the activities described in the statement.)
The Government has put forward these elements as guidance only rather than rigid minimum requirements because it is proposed that statements should not be a simple 'tick box exercise' but rather be relevant and specific to a companies’ own circumstances, therefore differing from business to business.
Those companies within the threshold boundary would benefit now from reviewing their systems and collating information ahead of the requirements coming into force, especially as statements will need to be signed off by company boards and directors.