THE MODERN SLAVERY ACT 2015

What is it ?

The UK Parliament implemented The Modern Slavery Act 2015 to confront human trafficking and modern slavery. Using both existing legislation and new measures, the Act specifically targets organisations and their supply chains.

Who does the Modern Slavery Act apply to?

Government guidance states that

“Every organisation carrying on a business in the UK with a total annual turnover of £36m or more will be required to produce a slavery and human trafficking statement for each financial year of the organisation.”

Any organisation in any part of a group structure will be required to comply with the provision and produce a statement if they:

  • are a body corporate or a partnership (described as an “organisation” in this document), wherever incorporated;

  • carry on a business, or part of a business, in the UK;

  • supply goods or services; and

  • have an annual turnover of £36m or more.

Total turnover is calculated as:

  • the turnover of that organisation; and

  • the turnover of any of its subsidiary undertakings (including those operating wholly outside the UK).

“Turnover” means the amount derived from the provision of goods and services falling within the ordinary activities of the commercial organisation or subsidiary undertaking, after deduction of:

  • trade discounts;

  • value added tax; and

  • any other taxes based on the amounts so derived.

What is included in a modern slavery statement?

There is no fixed structure and content, however a typical modern slavery statement will include a number of elements. It represents the organisation’s report to the outside world of the steps being taken to ensure that slavery does not exist in the business or it’s supply chain.

As a guide the following sections might be found in a high quality modern slavery statement:

  1. An introduction to the organisation confirming it’s commitment to the eradication of slavery and trafficking in all forms.

  2. Overview of the organisation, it’s structure and supply chains.

  3. Modern slavery governance. A specific section of the statement detailing the structure and management roles and responsibilities within the organisation in relation to modern slavery.

  4. A link to relevant organisation policies.

  5. Supply chain due diligence. An explanation of the due diligence that is carried out on suppliers.

  6. A summary of the approach taken to training and raising awareness of the issue of slavery and trafficking amongst staff of the organisation.

  7. Key performance indicators that are used within the organisation to monitor progress in relation to modern slavery management.

  8. An action plan of initiatives that are in place and or are planned for the next year.

Posted in Modern Slavery.

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