It is now over two years since the Modern Slavery Act 2015 was introduced, seeking to address the role that businesses take in preventing the occurrence of slavery and human trafficking in their supply chains and organisations. One of the ways it seeks to achieve this, is by requiring businesses with a total annual turnover of £36m or more, to produce a statement each financial year to detail what, if any, steps are being taken to combat the issues.
You can read further details on the scope of the Act here – but how successful has this regime been so far?
Are businesses complying?
What’s the risk?
As the above reports highlight, there are clearly many businesses which are failing to comply. Although there are currently no sanctions for non-compliance with the requirements of the Act, a business could encounter reputational damage if it fails to show that it is taking active steps to prevent the occurrence of slavery and human trafficking within its supply chain.
There are also potential changes on the horizon. The Modern Slavery (Transparency in Supply Chains) Bill, if enacted, may introduce a number of notable amendments to the Act including:
What should organisations be doing now?
Those organisations with the relevant level of turnover should clearly take steps to ensure compliance with the Act as soon as possible. However, all organisations whether currently affected or not, should watch this space. If the Bill is enacted, organisations may need to re-consider their current modern slavery policies and the scope of any statements they must produce.
Organisations not currently caught by the Act should also consider their part in supporting other organisations in the supply chain, as they could be called upon to assist in assessing the steps being taken to tackle the issues of slavery and human trafficking.
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