Government set to recruit business to assist in its ongoing battle with modern slavery
The Modern Slavery Act ("the Act") was granted royal assent on 26 March 2015.
Amongst other things, the Act will establish an Anti-Slavery Commissioner, consolidate trafficking and slavery offences and make provision for protection for the victims of modern slavery. The Act will also impact business by encouraging them to make themselves accountable for their own business practices throughout their supply chain.
The Government's hope is that the process of self evaluation in businesses will be achieved through a reporting obligation upon certain businesses within the Act. It is thought that the reporting obligation will only apply to large businesses (i.e. businesses with an annual turnover of £36,000,000 or more). Qualifying businesses will be required to make a statement for each financial year stipulating the steps it has taken to ensure that their business and supply chains are slavery free or, alternatively, that it has taken no such steps. All businesses required to make a statement must include a prominent link to this statement on its website.
From October 2015, the statement will need to include things such as:
- Information about training provided to those in supply chain management;
- The principle risks related to slavery and human trafficking in the business and its supply chain;
- Relevant key performance indicators regarding the effectiveness of what is described in the statement, with a view to showing progress year on year;
- A statement regarding its business model and supply chain relationships; and
- A statement regarding policies relating to modern slavery, including due diligence and auditing processes implemented.
One of the aims behind the Act is that the transparency created as a result of this reporting obligation, will provide investors and customers with the information to establish whether more action is required. It is also hoped that it will create more awareness for the issue of modern slavery.
The reporting obligation has a provisional implementation date of October 2015. If you are a business with a large turnover you may want to consider steps that you will take upon implementation to evaluate your supply processes now so as to avoid the potential for bad publicity that may occur as a result of failure to comply with the Act.