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The Modern Slavery Act 2015

The Modern Slavery Act 2015 was introduced at the end of last year to consolidate the law on slavery and human trafficking offences. It also establishes an Anti-Slavery Commissioner and introduces measures to support victims of slavery and trafficking offences.  However, the Act also brings about changes which directly affect the functioning of businesses on a day to day basis.

The reporting requirement

Any business which has a presence in the UK and an annual turnover of £36 million or more, is now required to prepare a slavery and human trafficking statement each financial year.  This requirement comes into effect for all relevant businesses for their first financial year ending on or after 31 March 2016. The government recommendation is that the report is produced within 6 months of the end of each organisation’s financial year.

The report, which is to be published on the organisation’s website, must set out any and all steps the business has taken to ensure that no slavery or trafficking is taking place within its supply chains or in any part of its operations. Where a business has taken no such steps, the report will need to state this.

The Act and associated guidance does not prescribe specific content for the statement but suggests that details such as the organisation’s structure, corporate policies, key risk areas, steps taken to prevent trafficking and training for employees, will be relevant.

The statement should be carefully verified to ensure that it is accurate and not misleading, particularly as directors who circulate a misleading statement run the risk of personal liability.  

What to do next?

To deal with the changes which this Act introduces, we recommend that you:

  • be prepared, as the requirement to report starts from your first financial year ending on or after 31 March 2016;
  • review your supply chain to understand the risks and exposure under the Act. Going forward, consider having clear procurement policies, contractual protections in supply contracts and consistent communication throughout the supply chain;
  • inform members of your supply chain of the changes and make sure they understand their responsibilities;
  • consider which senior individual(s) within the business will be responsible for ensuring compliance;
  • identify who will require training on the new obligations, for example, directors and employees who have direct responsibility for supply chain management and procurement; and
  • ensure there are effective grievance and whistleblowing mechanisms in place so that concerns over slavery and human trafficking may be raised and dealt with.

To speak to our Commercial team or for further details please call 0113 220 6270.

About the Author

Karen Crutchley

Partner

Karen is a Partner working in both the Commercial and Corporate teams.

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