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The Modern Slavery Act 2015 – taking stock

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?

  • The Chartered Institute of Procurement and Supply has found that a third of businesses required to produce a statement in compliance with the Act, have failed to do so.
  • The Business and Human Rights Resource Centre suggests that where businesses are producing a statement, many are failing to comply with specific requirements, such as ensuring that the statement is signed by a director and is published on the company’s website via a homepage link.

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:

  • Extending the requirement to produce a statement to public authorities
  • Prescribing mandatory information to include in a statement
  • Publication of a list of organisations required to produce a statement
  • Preventing an organisation from partaking in a procurement procedure under the Public Contracts Regulations 2015, where the organisation has failed to produce a statement.

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.

To speak to a member of our Commercial Team please call 0113 220 6270.