You may have heard about the new UK Modern Slavery Act 2015 and thought that slavery is an historic issue. However, according to the Global Slavery Index, in 2014 almost 36m people were living in modern slavery.
The Modern Slavery Act came into force on 1 November 2015 and, according to the Home Office, it is the first piece of legislation in Europe, and one of the first in the world, to specifically address slavery and trafficking in the 21st century. Apart from making provision for various slavery related criminal offences, the Act includes world-leading provisions to encourage businesses to take action to ensure their end-to-end supply chains are slavery free.
Should you be concerned?
The Act is of relevance to large businesses with a commercial presence in the UK whose worldwide turnover exceeds £36 million. If the Act applies to your business, then you will be required to publish an annual statement setting out the steps that have been taken to ensure that slavery and human trafficking is not taking place in:
- your supply chains; or
- any part of the business.
Dates for your calendar
Companies whose financial year ends on 31 March 2016 or later will be required to make a slavery and human trafficking statement within 6 months from the financial year end. If your organisation’s financial year ends no later than on 30 March 2016 then the Act won’t impact you until your next financial year.
The statement must be published prominently on the organisation's website (if it has one).
What should you do?
If the Act applies to your organisation, you will need a good understanding of your company’s supply chains in order make the slavery and human trafficking statement and to identify, assess and report on the risks.
You will need to consider:
- undertaking a business and supply chain review to determine the risks (e.g. locations);
- checking anti-slavery clauses in contracts with suppliers;
- developing a slavery and human trafficking statement;
- incorporating anti-slavery compliance into other policies and procedures (e.g. codes of conduct); and
- setting up a whistleblowing procedure for raising and reporting slavery concerns.
How can we help?
If you would like more information about how DMH Stallard can ensure you meet the requirements of the Modern Slavery Act 2015, then contact Giedre Jakubonyte.