Large commercial organisations which supply goods or services and with a turnover of at least £36 million, will need to publish an annual 'slavery and human trafficking statement' on their website. The statement will need to identify steps taken to ensure that modern slavery is not occurring in its business - or within a supply chain that it uses.
'Slavery and human trafficking' has a wide definition that includes the offences of slavery, servitude and forced or compulsory labour and human trafficking. As part of the government's crackdown on these offences, it will require eligible organisations to produce an annual statement that is written in plain English, is easily accessible to the general public, covers all of the necessary points and links to all relevant policies and procedures in place. Most importantly, the statement must include a statement of 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. If the organisation has not taken such steps then it should record that fact within the statement.
The organisation must include a link to the slavery and human trafficking statement in a prominent place on its website's homepage.
An eligible organisation must set out in the statement all the actions it has taken to ensure its supply chain and its business is free from slavery. As a result of this, it is likely that large organisations will want to see evidence of the steps taken by all of their suppliers within their supply chain of the steps that those suppliers have taken to minimise the risk of slavery and human trafficking within their own respective businesses. This does mean that any organisation - no matter how large - may need to prepare for questions being raised regarding slavery and human trafficking - perhaps by a client or Prime in the sector as part of compliance checks or when undertaking a tender process.
The relevant sections of the Modern Slavery Act became law on 29 October 2015. The obligation is being phased in and will require organisations to provide a statement within six months of their year-end that occurs on or after 31 March 2016.