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Large businesses are now legally obliged to state publicly each year the measures they have taken to ensure that their business and supply chains are free from modern slavery, according to a corporate lawyer.
“Modern slavery is acknowledged as a growing problem, and includes vulnerable people and children being forced to work against their will in poor conditions for very little pay,” says Philip Round, a partner at George Green LLP. “The Government now requires more sizeable enterprises to demonstrate how they are combatting this global crime.”
Mr Round continues, “The Modern Slavery Act 2015 requires commercial organisations with an annual turnover of at least £36m to prepare a Slavery and Human Trafficking Statement for each financial year. This requirement applies to both UK and non-UK organisations which carry on business or part of a business in the UK and covers bodies corporate and partnerships.”
According to Mr Round, businesses to which the legislation applies must prepare a Slavery and Human Trafficking Statement for financial years commencing on or after 31 March 2016. “There is, however, no prescribed time limit in which to make the statement. Businesses must do so as soon as reasonably practicable after the end of the relevant financial year, and are encouraged to do so within six months of the financial year end.”
“The Act does not stipulate a particular form or length for the statement. It must, however, either state the steps that the organisation has taken during the financial year to ensure that human trafficking and slavery are not present in any part of its business or supply chain, or that the organisation has taken no such steps. Relevant measures may include due diligence on suppliers and training for staff on how to detect modern slavery. All relevant businesses with a website must publish a statement on that site and include a prominent link to it on their home page. Businesses without an on-line presence must supply a copy of the statement to anyone on request.”
Mr Round concludes, “The Secretary of State may seek an injunction against businesses who fail to comply with their obligations, requiring them to do so. Perhaps more importantly, businesses who fail to take the appropriate measures are likely to face significant adverse publicity. It is therefore crucial for businesses to be aware of their legal duties and to ensure that they put in place effective measures to identify and eradicate slavery and human trafficking.”